Lacey Reece v. Carolyn Colvin
2016 U.S. App. LEXIS 15549
| 8th Cir. | 2016Background
- Claimant Lacey Reece applied for SSI in 2009 alleging disabling back, leg, and pulmonary problems; application denied after administrative hearings and remand for VE testimony; district court affirmed and claimant appealed.
- Treating physician Dr. James Robinette completed a 2013 Medical Source Statement finding limited stamina, inability to maintain full-time work, and absenteeism over three days/month, but also noted no limits on standing/walking/sitting and ability to lift 20 lbs.
- Consultative examiner Dr. Raymond Valdes found mild-to-moderate limitations: lumbar flexion limited to 75 degrees, 85% left-hand grip, normal gait, negative straight-leg raises, and ability to walk without assistive device; two state agency physicians concurred that claimant could perform a range of light work.
- At the ALJ hearing a vocational expert testified claimant could perform light jobs (small parts packer, cleaner/polisher, assembler) with restrictions on ladders and extreme temperatures; jobs would not be available if claimant missed more than three days/month or required lying down during the workday.
- The ALJ adopted an RFC for light work with occasional postural limitations and environmental restrictions, rejected Dr. Robinette’s opinion as inconsistent with objective evidence, daily activities, treatment notes, and consultative/state opinions, and found claimant not disabled.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ erred in discounting treating physician’s opinion | Reece: ALJ failed to give good reasons for rejecting Dr. Robinette’s finding that she lacks stamina and cannot maintain full-time work | Commissioner: ALJ properly discounted the opinion because it conflicted with objective findings, treatment notes, activities, and consultative/state opinions | Court: Affirmed — ALJ gave good reasons and substantial evidence supports discounting the treating opinion |
| Whether substantial evidence supports RFC and non‑disability finding | Reece: Record supports disability given reported pain and treating opinion | Commissioner: RFC supported by consultative exam, state reviewers, VE testimony, and claimant’s activities | Court: Substantial evidence supports RFC and non‑disability determination |
Key Cases Cited
- Hamilton v. Astrue, 518 F.3d 607 (8th Cir. 2008) (treating physician opinion may be discounted if inconsistent with other substantial evidence; ALJ must give good reasons)
- Cline v. Colvin, 771 F.3d 1098 (8th Cir. 2014) (ALJ may give less deference to treating opinion based primarily on claimant’s subjective complaints)
- Fredrickson v. Barnhart, 359 F.3d 972 (8th Cir. 2004) (lack of complaints to treating physician detracts from disability allegations)
- Dunahoo v. Apfel, 241 F.3d 1033 (8th Cir. 2001) (daily activities inconsistent with disabling pain may undermine credibility)
- Crawford v. Colvin, 809 F.3d 404 (8th Cir. 2015) (review of ALJ’s decision is for substantial evidence on the record as a whole)