Lora Hamman v. Carolyn W. Colvin
680 F. App'x 493
| 8th Cir. | 2017Background
- Lora Hamman applied for Social Security disability insurance benefits alleging disability from August 2008 due to physical (fibromyalgia, possible small fiber neuropathy, IBS, gastritis, thyroid nodules, tachycardia) and mental impairments (depression, anxiety, personality disorder).
- ALJ held a hearing with Hamman and a vocational expert, then found several severe impairments but determined Hamman retained the RFC for a reduced range of sedentary work.
- ALJ discounted Hamman’s symptom statements as "not entirely credible" and gave "little weight" to her treating physician Dr. Varadhachary’s medical source statement as unexplained and not supported by objective findings.
- Based on the RFC and vocational testimony, ALJ concluded Hamman could perform jobs existing in significant numbers and denied benefits; Appeals Council declined review.
- District court affirmed; the Eighth Circuit majority affirmed, finding the ALJ’s decision supported by substantial evidence. A dissent argued remand was required because the somatoform diagnosis, obtained late and not explained in the psychologist’s report, might change the credibility analysis and needed further development.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ improperly rejected treating physician opinion | Hamman: ALJ erred in discounting Dr. Varadhachary’s opinion, which supported disability | ALJ: Opinion is unexplained, consists of checked boxes/conclusory statements, and conflicts with other record evidence | Affirmed—ALJ permissibly declined controlling weight due to lack of explanation and inconsistent record evidence |
| Whether ALJ erred in adverse credibility finding given somatoform disorder | Hamman: ALJ improperly faulted her for lack of objective support; somatoform disorder can explain discrepancy | ALJ: Credibility also undermined by conservative treatment and daily activities inconsistent with disabling reports | Affirmed—any error regarding reliance on lack of objective findings was harmless because other substantial evidence supports credibility finding |
| Whether record required further development after late somatoform diagnosis | Hamman: Late, unexplained somatoform diagnosis requires remand for further development | Government: ALJ considered the psychologist’s diagnosis and other record evidence sufficed | Affirmed—majority: ALJ considered the diagnosis and record was adequate; dissent would remand for further development |
| Whether substantial evidence supports denial of benefits | Hamman: Record supports finding of disability when symptoms credited | ALJ: RFC and vocational testimony show ability to perform work in national economy | Affirmed—substantial evidence supports the ALJ’s RFC and denial of benefits |
Key Cases Cited
- Smith v. Colvin, 756 F.3d 621 (standard of review: substantial evidence)
- Teague v. Astrue, 638 F.3d 611 (substantial-evidence review framework)
- Williams v. Sullivan, 960 F.2d 86 (definition of substantial evidence)
- Krogmeier v. Barnhart, 294 F.3d 1019 (treating physician controlling-weight rule)
- Holmstrom v. Massanari, 270 F.3d 715 (limited value of checklist/checked-box opinions)
- Goff v. Barnhart, 421 F.3d 785 (weighing opinion evidence against record)
- Chaney v. Colvin, 812 F.3d 672 (harmlessness of certain credibility errors)
- Turpin v. Colvin, 750 F.3d 989 (conservative treatment and activities as credibility evidence)
- Easter v. Bowen, 867 F.2d 1128 (somatoform disorder—cannot discredit solely for lack of objective findings)
- Nowling v. Colvin, 813 F.3d 1110 (somatoform disorders may be debilitating despite minimal objective medical support)