Linda Lawson v. Carolyn W. Colvin
2015 U.S. App. LEXIS 21206
| 8th Cir. | 2015Background
- Linda Lawson applied for Social Security Disability Insurance and SSI claiming multiple mental disorders, alleging disability beginning April 13, 2009.
- Administrative Law Judge (ALJ) held hearings (Dec 2010, Mar 2011) and denied benefits, finding Lawson has a severe personality disorder but is not disabled; RFC limited to work with little/no public contact and superficial coworker/supervisor interaction.
- ALJ gave great weight to non‑examining psychiatrist Dr. Alfred Jonas (record reviewer/testifier) and little weight to treating psychiatrist Dr. Henry Wisdom and to "other" medical sources (nurse practitioner Mark Hensley and counselors Gordon Leach and Roy Lovell).
- ALJ discounted a low GAF score attributed to Lawson as inconsistent with treatment notes, consultative exam, and Lawson’s daily activities (care of children, household chores, driving, shopping, outdoor activities).
- District court affirmed; the Eighth Circuit reviewed de novo and affirmed, holding the ALJ’s weighing of medical opinions was supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ improperly discounted treating psychiatrist Dr. Wisdom’s opinion | Lawson: ALJ failed to discuss or give proper weight to Dr. Wisdom’s opinions (including low GAF) | Commissioner: Dr. Wisdom’s records are limited (7 brief med‑ management notes), contain improvement on meds, and give no concrete functional limitations | ALJ did not err: gave valid reasons (limited/brief visits, inconsistent GAF, improvement with treatment); substantial evidence supports discounting |
| Whether ALJ failed to consider or improperly rejected opinions from other medical sources (Hensley, Leach, Lovell) | Lawson: ALJ ignored or failed to weigh therapists’ and nurse practitioner’s opinions that supported disability | Commissioner: These providers are "other" medical sources (not acceptable medical sources); their opinions conflicted with record and claimant’s functioning; ALJ considered and permissibly discounted them | ALJ properly considered and gave little weight to those ‘‘other’’ medical sources because their opinions were inconsistent with the record and claimant’s demonstrated abilities |
Key Cases Cited
- Lacroix v. Barnhart, 465 F.3d 881 (8th Cir. 2006) (standard of appellate review for ALJ disability determinations)
- Milam v. Colvin, 794 F.3d 978 (8th Cir. 2015) (substantial evidence standard explained)
- Turpin v. Colvin, 750 F.3d 989 (8th Cir. 2014) (permissible to discount treating physician when other assessments are better supported)
- Prosch v. Apfel, 201 F.3d 1010 (8th Cir. 2000) (treating‑physician weight principles)
- Casey v. Astrue, 503 F.3d 687 (8th Cir. 2007) (consider length and frequency of treatment when weighing opinions)
- Jones v. Astrue, 619 F.3d 963 (8th Cir. 2010) (GAF and credibility considerations)
- Wildman v. Astrue, 596 F.3d 959 (8th Cir. 2010) (impairments controlled by treatment are not disabling)
- Brown v. Barnhart, 390 F.3d 535 (8th Cir. 2004) (daily activities can undermine claims of disabling impairment)
- Raney v. Barnhart, 396 F.3d 1007 (8th Cir. 2005) (ALJ has discretion in weighing "other medical evidence")
- Sloan v. Astrue, 499 F.3d 883 (8th Cir. 2007) (distinction between acceptable medical sources and other sources)