Lisa Austin v. Kilolo Kijakazi, 52 F.4th 723

Lisa Austin applied for Title II disability benefits on March 27, 2018, alleging disability beginning February 28, 2018; claim denied administratively and by an ALJ after a hearing.
Primary impairment: chronic migraines; she received an implanted spinal cord neurostimulator in April 2018 and reported significant improvement, though she continued intermittent treatment for headaches through July 2019.
Secondary impairments: depression and anxiety. Dr. Kristin Addison-Brown (neuropsychologist) found moderate recurrent MDD, possible ADHD, and high prescription-abuse risk; Dr. Dennis Vowell (psychologist) diagnosed MDD but found no significant adaptive-functioning limits; state consultant Dr. Bucolo concluded claimant could do light work with limited interpersonal contact.
ALJ found severe impairments (migraines, anxiety, mood disorder), concluded claimant has RFC for light work with restrictions (avoid extreme cold/wetness, direct sunlight, loud noises), cannot do past school-counselor work but can perform other jobs; denied benefits from Feb 28, 2018 through Feb 5, 2020.
Appeals Council declined review; district court affirmed; Austin appealed to the Eighth Circuit, arguing (1) improper evaluation of medical opinions and (2) RFC insufficiently accounted for ongoing headaches.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly evaluated the persuasiveness of medical opinions (Addison-Brown and Vowell) under 20 C.F.R. § 404.1520c	ALJ failed to conduct a proper persuasiveness analysis of Dr. Addison-Brown and improperly ignored parts of Dr. Vowell’s opinion	ALJ reasonably discounted Addison-Brown for limited support, inconsistency with record, and single consult; ALJ permissibly accepted parts of Vowell’s opinion	ALJ did not commit legal error; persuasiveness analysis adequate; any error re: Addison-Brown harmless because opinion did not address migraines
Whether the RFC is supported by substantial evidence given ongoing migraine limitations after neurostimulator implantation	ALJ erred in finding the neurostimulator largely controlled symptoms and in not including additional functional limits for headaches	Record shows significant post‑op improvement, limited treatment after July 2019, claimant’s daily activities, and RFC includes environmental restrictions that address headache triggers	RFC is supported by substantial evidence and lies within the ALJ’s permissible zone of choice; environmental limits accounted for triggers

Kraus v. Saul, 988 F.3d 1019 (8th Cir. 2021) (standards for appellate review and substantial-evidence review)
Schmitt v. Kijakazi, 27 F.4th 1353 (8th Cir. 2022) (RFC must be based on all relevant evidence; review for substantial evidence)
Bowers v. Kijakazi, 40 F.4th 872 (8th Cir. 2022) (revised § 404.1520c persuasiveness framework; treating-source rule no longer controlling)
Grindley v. Kijakazi, 9 F.4th 622 (8th Cir. 2021) (harmless-error doctrine where clarification would not have changed outcome)
Mabry v. Colvin, 815 F.3d 386 (8th Cir. 2016) (ALJ may accept parts of a medical opinion and reject others)
Clay v. Barnhart, 417 F.3d 922 (8th Cir. 2005) (ALJ resolves conflicts among expert opinions)
Walker v. Comm’r, Soc. Sec. Admin., 911 F.3d 550 (8th Cir. 2018) (discussed treating-physician rule; distinguished here as inapplicable under revised regs)
Moad v. Massanari, 260 F.3d 887 (8th Cir. 2001) (lack of recent treatment can undercut complaints of disabling pain)
Nash v. Comm’r, Soc. Sec. Admin., 907 F.3d 1086 (8th Cir. 2018) (daily activities can discredit testimony alleging inability to work)
Miles v. Harris, 645 F.2d 122 (2d Cir. 1981) (no requirement to reconcile every conflicting shred of evidence)