Renstrom v. Astrue
680 F.3d 1057
8th Cir.2012Background
- Renstrom sought disability benefits for back, neck, sleep apnea, anxiety; alleged onset Sept 13, 2002.
- ALJ found RFC for light work with one-hour position change; denied benefits.
- Medical history includes L4-L5 herniation, fusion, later instrument removal; multiple surgeries and PT.
- Treating physicians provided mixed opinions, notably Dr. Agre (opined total disability) and others supporting light work.
- Consultative and agency physicians largely supported light work; credibility and objective findings weighed against pain claims.
- Appeals and district court affirmed, concluding substantial evidence supports the ALJ’s decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RFC proper weight to treating opinions | Agre’s opinion should control; Schwender supported; AGRE consistent with record. | ALJ properly discounted Agre as based on subjective complaints; other evidence supports light work. | ALJ appropriately weighed medical opinions; RFC supported by substantial evidence. |
| Credibility of Renstrom's subjective complaints | ALJ erred by discounting pain testimony without adequate reasons. | ALJ properly discounted complaints using Polaski factors and treatment response. | Credibility properly analyzed; substantial evidence supports discounting testimony. |
| Reliance on vocational expert | Hypothetical failed to include all limitations from Renstrom's impairments. | Hypothetical incorporated supported RFC; VE testimony consistent with record. | VE testimony based on proper RFC; substantial evidence supports denial. |
| Substantial gainful activity determination | Earnings in 2002–2003 may stem from retirement/benefits, not SGA. | ALJ’s SGA finding rendered any error harmless given last insured date. | Any error harmless; denial upheld within the relevant period. |
Key Cases Cited
- Teague v. Astrue, 638 F.3d 611 (8th Cir. 2011) (ALJ may discount a treating opinion when inconsistent with evidence)
- Pearsall v. Massanari, 274 F.3d 1211 (8th Cir. 2001) (ALJ resolves conflicts among physicians' opinions)
- Partee v. Astrue, 638 F.3d 860 (8th Cir. 2011) (ALJ may weigh credibility factors and evidence support)
- Martise v. Astrue, 641 F.3d 909 (8th Cir. 2011) (Hypotheticals need only include supported impairments)
- Jones v. Astrue, 619 F.3d 963 (8th Cir. 2010) (Hypothetical must reflect substantial evidence)
- Wildman v. Astrue, 596 F.3d 959 (8th Cir. 2010) (Limitations from discredited opinions need not be included)
- Juszczyk v. Astrue, 542 F.3d 626 (8th Cir. 2008) (Credibility determinations require Polaski factors)
- Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (Factors for evaluating pain with credibility)
- Brown v. Astrue, 611 F.3d 941 (8th Cir. 2010) (Treatment can control impairment; not disabling if controlled)
- Halverson v. Astrue, 600 F.3d 922 (8th Cir. 2010) (Inconsistencies support reduced credibility)
- Choate v. Barnhart, 457 F.3d 865 (8th Cir. 2006) (Disability determinations reside with Commissioner; opinions reviewed)
- Gonzales v. Barnhart, 465 F.3d 890 (8th Cir. 2006) (Review of substantial evidence standard)
- Moore v. Astrue, 572 F.3d 520 (8th Cir. 2009) (Deference to ALJ credibility findings with substantial evidence)
- Van Vickle v. Astrue, 539 F.3d 825 (8th Cir. 2008) (Harmless error when disability determination remains)
- Craig v. Apfel, 212 F.3d 433 (8th Cir. 2000) (ALJ not required to discuss every piece of evidence)