Stanfel v. Social Security Administration
3:17-cv-00225
E.D. Ark.Apr 30, 2018Background
- Dana Stanfel applied for Supplemental Security Income on November 12, 2014, alleging disability since November 29, 2006; the ALJ denied benefits and the Appeals Council denied review.
- ALJ found Stanfel had severe impairments: osteoarthritis, degenerative disc disease, diabetes, obesity, affective and anxiety disorders, but did not meet a listing.
- ALJ assessed an RFC for the full range of light work with limitations: occasional stoop/kneel/crouch/crawl and only simple, routine tasks with incidental interpersonal contact.
- ALJ gave little weight to treating PCP Kristi Statler, M.D.’s checkbox opinion that Stanfel could not perform light work and had marked mental limitations, citing lack of objective support and conservative treatment.
- Vocational Expert testified Stanfel could perform jobs (merchandise marker, routing clerk); ALJ found her not disabled and the district court affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether RFC failed to include all limitations | Stanfel: RFC omitted limitations opined by treating physician (no light work, frequent position changes, extended breaks). | Commissioner: RFC accounted for limitations supported by record; Dr. Statler’s opinion was unsupported and conclusory. | Court: RFC supported by substantial evidence; incorporated appropriate limitations. |
| Weight given to treating physician Dr. Statler | Stanfel: ALJ improperly discounted treating opinion. | Commissioner: ALJ permissibly gave little weight due to checkbox form, lack of objective findings, and limited treating relationship. | Court: ALJ properly discounted Dr. Statler’s opinion. |
| Credibility of symptom allegations (pain, mental limitations) | Stanfel: symptoms are disabling. | Commissioner: Normal imaging, conservative treatment, positive response to meds/treatment, daily activities undermine disabling claims. | Court: ALJ reasonably discounted severity of subjective complaints; credibility findings supported. |
| Step five reliance on VE testimony | Stanfel: vocational finding unreliable if RFC incomplete. | Commissioner: VE jobs consistent with RFC and transferable to national economy. | Court: VE testimony supported ALJ’s step-five determination; not disabled. |
Key Cases Cited
- Prosch v. Apfel, 201 F.3d 1010 (8th Cir. 2000) (substantial-evidence standard for review)
- Slusser v. Astrue, 557 F.3d 923 (8th Cir. 2009) (definition of substantial evidence)
- Long v. Chater, 108 F.3d 185 (8th Cir. 1997) (court may not reverse when substantial evidence supports ALJ)
- Gowell v. Apfel, 242 F.3d 793 (8th Cir. 2001) (normal objective testing weighs against disabling pain)
- Davidson v. Astrue, 578 F.3d 838 (8th Cir. 2009) (evidence of malingering supports discounting complaints)
- Mittlestedt v. Apfel, 204 F.3d 847 (8th Cir. 2000) (controllable impairments do not establish total disability)
- Smith v. Shalala, 987 F.2d 1371 (8th Cir. 1993) (conservative treatment contradicts disabling pain)
- Moore v. Astrue, 572 F.3d 520 (8th Cir. 2009) (physician’s recommendation to exercise indicates greater functional capacity)
- Anderson v. Astrue, 696 F.3d 790 (8th Cir. 2012) (conclusory checkbox forms have little evidentiary value)
- Cline v. Colvin, 771 F.3d 1098 (8th Cir. 2014) (ALJ may discount medical opinions based largely on subjective complaints)
- Gwathney v. Chater, 104 F.3d 1043 (8th Cir. 1997) (failure to seek regular mental-health treatment undermines disability claim)
- Shannon v. Chater, 54 F.3d 484 (8th Cir. 1995) (daily activities may undermine disability claims)
- Edwards v. Barnhart, 314 F.3d 964 (8th Cir. 2003) (same)