Mike Winn v. Commissioner, Social Security, 894 F.3d 982

Winn applied for SSDI covering June 12, 2007 (onset) through December 31, 2012 (date last insured); his claim was denied after hearings and remands; district court upheld the denial and Winn appealed.
ALJ found severe impairments: cervical degenerative disc disease, carpal tunnel, and neuropathy, and formulated an RFC for light work with various postural and manipulative limits (e.g., lift 10/5 lbs, sit/stand up to 6 hours, frequent handling/fingering but only occasional overhead reach).
Medical history: MRIs showed cervical stenosis; specialists (Parker, Havey, Meyer) performed cervical fusion and carpal tunnel surgeries in 2007–2009 and generally reported postoperative improvement and allowed light work; some tests and later consultative exam (Dr. Velez) showed normal ROM and full sensation, with possible right-hand manipulative limitation.
Treating internist Dr. LaMonda (longstanding treating physician) opined in 2010 that Winn had significant, permanent limitations (e.g., could not sit >30 minutes, needed to lie down every 2 hours, limited to 10-lb lifting and no repetitive use) and later reaffirmed that nerve damage was permanent.
ALJ gave limited weight to Dr. LaMonda’s restrictive opinions (except 10-lb lift limit), gave significant weight to the specialists’ opinions and partial weight to Drs. Kitchens and Velez; found Winn could not do past heavy-equipment work but could perform other jobs per VE testimony and therefore was not disabled.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ erred in discounting treating physician Dr. LaMonda’s opinions	LaMonda treated Winn >20 years and coordinated care; his 2010 opinions require controlling weight and reflect progressive decline after specialists’ earlier opinions	ALJ: LaMonda’s restrictive opinions lack objective support and conflict with specialists’ findings and later consultative exam; may be discounted	Affirmed — ALJ permissibly gave limited weight to LaMonda (except 10-lb lift) because his extreme limitations were unsupported by objective evidence and conflicted with other medical opinions
Whether RFC’s manipulative finding ("frequent" handling/fingering) failed to account for Dr. Velez’s opinion of possible right-hand limitation	Winn: Velez’s credited opinion indicates manipulative limits that would require "occasional" (not "frequent") handling, which would eliminate some VE jobs	Commissioner: ALJ credited Velez but reasonably construed his opinion as consistent with "frequent" handling; VE identified alternate job if only "occasional" handling applied	Affirmed — ALJ’s RFC was consistent with record and VE identified work even under "occasional" limitation; no reversible error

Van Vickle v. Astrue, 539 F.3d 825 (8th Cir. 2008) (substantial-evidence standard of review)
Johnson v. Astrue, 628 F.3d 991 (8th Cir. 2011) (treating-physician controlling-weight standard)
Gieseke v. Colvin, 770 F.3d 1186 (8th Cir. 2014) (ALJ may discount treating opinions unsupported by objective evidence)
Hacker v. Barnhart, 459 F.3d 934 (8th Cir. 2006) (ALJ resolves conflicts and credibility)
Andrews v. Colvin, 791 F.3d 923 (8th Cir. 2015) (court defers when substantial evidence supports ALJ even if record could support contrary outcome)
Cox v. Astrue, 495 F.3d 614 (8th Cir. 2007) (RFC is an administrative determination reserved to the Commissioner)