46 F.4th 686
8th Cir.2022Background:
- Melissa A. Galloway applied for Title II disability insurance benefits with an amended onset date of February 27, 2017; the SSA denied benefits and an ALJ held a hearing in May 2019.
- The ALJ found severe impairments including depression and anxiety and assessed a moderate limitation in understanding, remembering, or applying information.
- The ALJ’s RFC limited Galloway to light work with the ability to understand, remember, and carry out simple instructions, make simple work‑related decisions, handle routine changes, and have occasional contact with others.
- Treating mental‑health providers (Rund and Rock) checked forms indicating marked limitations in understanding, remembering, and carrying out detailed instructions; the ALJ gave their joint opinion only partial weight, calling it not necessarily pertinent because the claimant was limited to simple, unskilled work.
- A vocational expert testified that a person with the ALJ’s stated limitations could perform assembler, hand packager/inspector, and mail sorter positions in the national economy.
- The ALJ concluded Galloway was not disabled; the Appeals Council denied review and the district court upheld the denial. The Eighth Circuit affirmed.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ’s hypothetical and RFC omitted a finding that Galloway cannot follow detailed instructions, creating a conflict with DOT job requirements | Galloway: ALJ intended to find she lacked ability to follow detailed instructions but failed to include that limitation in the hypothetical/RFC, so VE testimony conflicts with DOT listings | Comm’r: ALJ’s language can be harmonized with the RFC/hypothetical; ALJ did not find inability to follow detailed instructions, so no conflict exists | Court: The disputed sentence can be harmonized with the RFC and hypothetical; no apparent conflict with the DOT exists, so VE testimony is substantial evidence |
| Whether the ALJ insufficiently explained discounting the treating mental‑health providers’ opinion that Galloway had marked limitations with detailed instructions | Galloway: ALJ gave only partial weight without adequate explanation why Rund/Rock’s marked‑limitation opinion was discounted | Comm’r: Rund and Rock are not acceptable medical sources, their opinion was a checklist lacking objective support and inconsistent with treatment notes, so discounting was proper | Court: ALJ permissibly gave the opinions limited weight because they were checklist forms with scant objective support and inconsistent treatment notes; substantial evidence supports the decision |
Key Cases Cited
- Stanton v. Commissioner, Social Security Admin., 899 F.3d 555 (8th Cir. 2018) (standard of review and substantial‑evidence framework)
- Haggard v. Apfel, 175 F.3d 591 (8th Cir. 1999) (VE testimony from properly phrased hypothetical is substantial evidence)
- Moore v. Astrue, 623 F.3d 599 (8th Cir. 2010) (no direct conflict between simple instructions and jobs with "detailed but uninvolved" instructions)
- Lucy v. Chater, 113 F.3d 905 (8th Cir. 1997) (dicta suggesting possible conflict between simple and detailed instructions)
- Chismarich v. Berryhill, 888 F.3d 978 (8th Cir. 2018) (deferential review requires harmonizing potentially inconsistent findings)
- Swarthout v. Kijakazi, 35 F.4th 608 (8th Cir. 2022) (checklist medical forms entitled to relatively little evidentiary value)
- Wildman v. Astrue, 596 F.3d 959 (8th Cir. 2010) (conclusory checklist forms that cite no medical evidence may be discounted)
- Davidson v. Astrue, 578 F.3d 838 (8th Cir. 2009) (ALJ may discount a treating opinion inconsistent with the provider’s clinical notes)