Renee Toland v. Carolyn W. Colvin, 761 F.3d 931

Renee Toland applied for DIB and SSI alleging disability from degenerative disc disease, back pain with sciatica, and shoulder limitations, claiming inability to work since December 13, 2007.
Treating records: Dr. Chris Cobb noted chronic back pain since 2006, described mostly mild/intermittent pain, normal gait and spinal mobility at several visits, and recommended limited exercises; MRI showed degenerative disc disease and mild bulge.
Pain specialist Dr. Butchaiah Garlapati treated Toland starting Sept. 2009, prescribed analgesics, and in March 2011 completed a Medical Source Statement (MSS) limiting Toland to lifting <10 lbs, standing <2 hours/day, use of a handheld assistive device, need to alternate sit/stand, and multiple environmental restrictions.
Consultative examiner Dr. Ted Honghiran (Jan. 2010) and two state agency reviewers concluded Toland cannot do heavy landscaping work but can perform less physically demanding jobs (RFC: lift 10 lbs frequently/20 lbs occasionally; sit/stand ~6 hours; occasional stooping/kneeling; no overhead reaching with right arm).
At hearing Toland reported sitting 30–45 minutes and standing 5–10 minutes, walking ~20 minutes, and some daily activities including part-time garden-center work and household chores; VE identified sedentary jobs (food checker, ticket seller) consistent with ALJ’s RFC.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ erred in discounting treating physician Garlapati’s MSS	Garlapati’s opinion shows greater limitations (standing, ambulation, environmental limits); ALJ should have given it controlling weight	ALJ reasonably discounted the MSS as inconsistent with treatment notes, claimant’s activities, and it was conclusory; relied on consultative and state reviewers	ALJ did not err; substantial evidence supports giving little weight to MSS and adopting RFC based on other medical opinions

Anderson v. Astrue, 696 F.3d 790 (8th Cir. 2012) (standard of review and requirement for ALJ to give good reasons for weight to treating opinion)
Jones v. Astrue, 619 F.3d 963 (8th Cir. 2010) (definition of substantial evidence)
Brown v. Barnhart, 390 F.3d 535 (8th Cir. 2004) (do not reverse when contrary substantial evidence exists)
Hogan v. Apfel, 239 F.3d 958 (8th Cir. 2001) (treating source opinion does not automatically control)
Hacker v. Barnhart, 459 F.3d 934 (8th Cir. 2006) (treating physician inconsistency can undermine opinion)
Teague v. Astrue, 638 F.3d 611 (8th Cir. 2011) (court may discount checklist opinions not supported by records)
Wildman v. Astrue, 596 F.3d 959 (8th Cir. 2010) (conclusory checkbox forms have little evidentiary value)
Dunahoo v. Apfel, 241 F.3d 1033 (8th Cir. 2001) (working or seeking work undermines claims of disabling pain)
Ludden v. Bowen, 888 F.2d 1246 (8th Cir. 1989) (claimant need not be bedridden to be disabled; inconsistencies with daily activity are relevant)
Goff v. Barnhart, 421 F.3d 785 (8th Cir. 2005) (part-time work is relevant to RFC determination)