Teague v. Astrue
638 F.3d 611
8th Cir.2011Background
- Teague sought disability insurance benefits for migraine headaches, affective mood disorder, and myofascial back pain.
- ALJ found Teague's residual functional capacity to be sedentary and concluded she could perform past relevant work.
- Appeals Council denied review; district court affirmed; Teague appeals the ALJ decision.
- Medical history spans 2005–2008 with repeated migraine complaints and depression treated by multiple physicians.
- Dr. Lowder provided a MSS post-denial asserting limited standing, sitting, and lifting, without objective testing cited.
- Consultative and other medical sources (Dr. Naseer, Dr. Moore, Dr. Kumar) showed mostly normal findings or limited objective evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ properly evaluated Teague's migraine testimony | Teague argues credibility undermined; headaches severely limit function. | ALJ found no substantial corroboration of pervasive debilitating headaches. | Substantial evidence supported ALJ's credibility assessment. |
| Whether ALJ properly weighed treating and consultative opinions | Lowder and Moore opinions should control due to treating source status and support. | Their opinions relied on subjective complaints or lacked objective support; other evidence favored the ALJ. | ALJ properly discounted Lowder and Moore opinions. |
| Whether Teague's residual functional capacity and past work finding are supported by substantial evidence | RFC overstated; migraines and back pain should limit work capacity; past work not compatible. | Record supports sedentary RFC and ability to perform past relevant work as customer service representative. | Yes; substantial evidence supports the ALJ's RFC and past-work finding. |
| Whether the MSS from Dr. Lowder provides legitimate functional limitations | MSS shows significant limitations tied to back pain. | MSS lacks objective testing and is inconsistent with other medical findings. | ALJ properly gave little weight to Lowder MSS. |
Key Cases Cited
- Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (factors for evaluating pain testimony)
- Eichelberger v. Barnhart, 390 F.3d 584 (8th Cir. 2004) (credibility may be undermined by inconsistency with record)
- Prosch v. Apfel, 201 F.3d 1010 (8th Cir. 2000) (treating physician opinions may be discounted when inconsistent with substantial evidence)
- Clark v. Apfel, 141 F.3d 1253 (8th Cir. 1998) (non-treating psychologist opinions not controlling)
- Masterson v. Barnhart, 363 F.3d 731 (8th Cir. 2004) (burden on claimant to prove disability; analysis of subjective complaints)
- Finch v. Astrue, 547 F.3d 933 (8th Cir. 2008) (standard for evaluating substantial evidence in disability determinations)