Teague v. Social Security Administration
1:16-cv-00153
E.D. Ark.Jun 8, 2017Background
- Plaintiff Joni Teague (age 53) applied for Supplemental Security Income alleging disability from April 25, 2014; she has no past relevant work and a GED.
- ALJ found severe impairments: degenerative disc disease, anger issues, depression, and bipolar disorder, but no listed impairment was met or equaled.
- ALJ assessed a Residual Functional Capacity (RFC) for a reduced range of light work with mental limitations and relied on a vocational expert to identify available jobs (small products assembler, mail clerk).
- ALJ discounted Teague’s subjective symptom testimony as not fully credible after applying Polaski factors and citing conservative treatment records and objective mental health evaluations.
- State psychological consultants (Drs. Kelley and Simon) and recent treatment notes supported non‑marked limitations and ability to perform simple, routine tasks.
- Appeals Council denied review; Magistrate Judge Volpe recommended affirming the Commissioner, finding the ALJ’s decision supported by substantial evidence and free of legal error.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credibility of subjective complaints | Teague says ALJ improperly discredited her pain and mental symptoms | ALJ applied Polaski factors, cited inconsistent objective evidence and conservative treatment | ALJ credibility finding upheld; supported by substantial evidence |
| RFC assessment (mental and physical) | RFC insufficiently accounts for mental and physical limitations | RFC supported by medical records and consultative psychologists’ opinions | RFC affirmed as consistent with record |
| Failure to develop the record | ALleges ALJ did not obtain needed medical evidence | Record was adequate for an informed decision; no prejudice shown | No duty breached; record development adequate |
| Step Five burden (jobs available) | Argues Commissioner failed to meet burden to show jobs exist | Vocational expert testimony established representative jobs | Step Five finding affirmed; not disabled |
Key Cases Cited
- Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (factors for evaluating claimant credibility)
- Richardson v. Perales, 402 U.S. 389 (1971) (definition of substantial evidence standard)
- Slusser v. Astrue, 557 F.3d 923 (8th Cir. 2009) (review standard for Commissioner’s decision)
- Schultz v. Astrue, 479 F.3d 979 (8th Cir. 2007) (deference to ALJ credibility findings)
- Reutter ex rel. Reutter v. Barnhart, 372 F.3d 946 (8th Cir. 2004) (substantial evidence review of disability determinations)
- Shelton v. Chater, 87 F.3d 992 (8th Cir. 1996) (affirming credibility determinations when supported by reasons)