Robert Crawford v. Carolyn W. Colvin
809 F.3d 404
| 8th Cir. | 2015Background
- Crawford, born Sept. 16, 1969, applied for SSI on Aug. 16, 2007, alleging multiple impairments (COPD, heart issues, obesity, sleep apnea, depression).
- Disability onset claimed as Jan. 1, 2004; initial SSA denial followed by ALJ denial and Appeals Council denial; district court reversed for lack of substantial evidence on past work and remanded.
- On remand, ALJ found Crawford not disabled, restricting him to sedentary work with specific RFC limits (lift/carry 10 pounds occasionally, stand/walk 2 hours, sit 6 hours, avoid respiratory irritants).
- Medical records (2007–2012) generally showed normal gait, ROM, memory, and lungs; inconsistencies between testimony and records led the ALJ to credit credibility loosely.
- Crawford challenges: (1) rejection of treating nurse practitioner Drummond’s opinion; (2) use of Medical-Vocational Guidelines at step five despite nonexertional impairments.
- Final result: district court affirmed; the Eighth Circuit affirms, holding the ALJ’s decision supported by substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly weighed Drummond’s NP opinion | Crawford argues Drummond’s opinion should be given controlling weight | ALJ can discount NP opinion as not from an acceptable medical source and inconsistent with other evidence | Yes; ALJ properly weighed and largely discounted inconsistent parts of Drummond's opinion |
| Whether use of the Medical-Vocational Guidelines was proper given nonexertional impairments | Crawford contends nonexertional limits (obesity, COPD) require VE testimony | Nonexertional limits do not preclude reliance on Guidelines when RFC supports sedentary work | Yes; Guidelines properly applied because nonexertional limits do not diminish sedentary RFC; no VE testimony needed |
Key Cases Cited
- Robinson v. Sullivan, 956 F.2d 836 (8th Cir. 1992) (burden shifted at step five to show ability to adjust to other work)
- LUCY v. CHATER, 113 F.3d 905 (8th Cir. 1997) (nonexertional impairments do not automatically bar use of Guidelines if RFC supports sedentary work)
- Eichelberger v. Barnhart, 390 F.3d 584 (8th Cir. 2004) (consideration of all symptoms and credibility; objective evidence governs weight given to subjective complaints)
- Goff v. Barnhart, 421 F.3d 785 (8th Cir. 2005) (discounting treating opinions when inconsistent with better evidence)
- Prosch v. Apfel, 201 F.3d 1010 (8th Cir. 2000) (treating opinions may be discounted for inconsistency or lack of supportive evidence)