Peterson v. Commissioner of Social Security
1:13-cv-00052
N.D. IowaJul 30, 2014Background
- Plaintiff Veronica J. Peterson (b.1971; eighth-grade education, special education history) applied for Title II disability insurance benefits alleging mental (bipolar/schizophrenia/ borderline personality disorder, PTSD, anxiety) and physical (degenerative L5–S1 disc, prior back surgery, hip osteoarthritis, chronic migraines) impairments beginning June 15, 2007.
- Administrative record includes multiple mental-health evaluations and hospitalizations (2004–2011), consultative physical and psychological exams, state agency reviews, and treatment notes from nurse practitioner Mark Snider and psychiatrist/clinician Rick Larsen (limited contact).
- At hearing Peterson testified to severe chronic low-back pain after April 2010 surgery, near-daily debilitating migraines, hearing voices, panic attacks, poor coping in groups, medication side effects (drowsiness, concentration problems), and variable daily functioning; VE testified that with sedentary/light RFC with limited contact and simple tasks, several jobs exist but one-third-day slow pace would preclude employment.
- The ALJ found severe impairments, adopted a sedentary RFC limiting pace, attention to detail, and social contact (simple, routine, repetitive work; occasional contact with others), found Peterson could not perform past work, but could perform other jobs existing in significant numbers — and therefore was not disabled.
- Plaintiff appealed, arguing the ALJ failed to properly weigh medical opinions (Dr. Larsen — treating psychiatrist, Dr. Stientjes — examining psychologist, and NP Snider) and improperly assessed her credibility. The magistrate judge affirmed, finding the ALJ’s reasoning supported by substantial evidence and the record fully developed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ's weighing of Dr. Larsen's opinion (mental RFC) | ALJ improperly discounted Larsen (treating specialist) and should have given greater weight to his severe limitations and opinion that Peterson would miss ≥4 days/month | Commissioner: Larsen had treated Peterson <3 months; opinion was a checklist form with little supporting objective data; weight properly reduced | Court: ALJ gave "good reasons" (short treatment relationship, lack of treatment records, form report) and substantial-evidence support for discounting Larsen's opinions; affirmed |
| ALJ's handling of Dr. Stientjes (examining psychologist) | ALJ erred in giving little weight to Stientjes’ opinion that sustained employment prospects are poor | Commissioner: ALJ permissibly relied on inconsistency between Stientjes' opinion and claimant’s recent SGA/work history and prior more-optimistic assessment | Court: ALJ reasonably relied on internal inconsistency and claimant's recent work; gave adequate reasons; affirmed |
| ALJ's consideration of NP Snider's June 2010 letter | ALJ failed to explicitly discuss Snider’s letter and implicitly rejected it without articulated basis | Commissioner: omission does not imply non-consideration; RFC already incorporated limitations similar to Snider’s vague statements; letter lacked treatment detail/support | Court: ALJ implicitly considered Snider (cited elsewhere), Snider’s letter was vague/unexplained, and RFC is supported by record; no remand required |
| Credibility of subjective complaints (Polaski factors) | ALJ improperly discredited Peterson’s symptom reports (pain, migraines, psychosis) | Commissioner: ALJ properly considered treatment gaps, noncompliance, improvement with consistent treatment, daily activities, and work history | Court: ALJ expressly considered Polaski factors, identified inconsistencies and noncompliance, provided good reasons for discounting credibility; affirmed |
Key Cases Cited
- Anderson v. Astrue, 696 F.3d 790 (8th Cir. 2012) (substantial-evidence standard for affirming Commissioner)
- Jones v. Astrue, 619 F.3d 963 (8th Cir. 2010) (definition of substantial evidence)
- Guilliams v. Barnhart, 393 F.3d 798 (8th Cir. 2005) (agency decision within a zone of choice upheld if supported by substantial evidence)
- Travis v. Astrue, 477 F.3d 1037 (8th Cir. 2007) (treating physician rule and assessing consistency/support)
- Strongson v. Barnhart, 361 F.3d 1066 (8th Cir. 2004) (ALJ may discount treating physician’s RFC if inconsistent with record)
- Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (factors for evaluating claimant’s subjective complaints)