Tim Walker v. Nancy A. Berryhill, 688 F. App'x 414

Tim Walker appealed the district court’s order affirming an ALJ decision that he was disabled from April 8, 2012 through January 31, 2014 but ceased to be disabled as of February 1, 2014.
The ALJ concluded medical improvement had occurred and that Walker’s residual functional capacity (RFC) had increased as of February 1, 2014.
The district court adopted the magistrate judge’s recommendation and affirmed the ALJ; this appeal challenges that affirmance.
The majority reviewed the record for substantial-evidence support for the ALJ’s findings on credibility, RFC, and medical improvement and affirmed.
The dissent argued the ALJ failed to compare Walker’s condition at the time of the original favorable decision with his condition as of February 1, 2014, and that the ALJ’s explanation was too conclusory to permit meaningful appellate review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether medical improvement occurred as of Feb 1, 2014	Walker: ALJ did not adequately compare current condition to condition when benefits were awarded; explanation insufficient	Commissioner: Record, including new evidence considered by Appeals Council, supports ALJ’s finding of medical improvement and increased RFC	Affirmed: substantial evidence supports ALJ’s determination of medical improvement beginning Feb 1, 2014 (majority)
Whether RFC and credibility findings were supported	Walker: ALJ’s RFC change unexplained, credibility findings inadequately justified	Commissioner: ALJ relied on medical records, treating observations, claimant statements; supported by evidence	Affirmed: ALJ’s RFC and credibility findings supported by substantial evidence
Whether remand is required for further explanation	Walker: remand necessary because ALJ’s opinion lacks the required comparative analysis	Commissioner: not necessary because record as a whole supports decision	Dissent would remand for further findings; majority declines and affirms

Harvey v. Colvin, 839 F.3d 714 (8th Cir. 2016) (review standard; substantial-evidence review of ALJ decision including Appeals Council evidence)
Hensley v. Colvin, 829 F.3d 926 (8th Cir. 2016) (RFC must be based on all relevant evidence; RFC is a medical question requiring medical support)
Mabry v. Colvin, 815 F.3d 386 (8th Cir. 2016) (deference to credibility findings supported by good reasons and substantial evidence)
Delph v. Astrue, 538 F.3d 940 (8th Cir. 2008) (steps in sequential analysis for cessation of benefits and medical improvement standard)
Scott ex rel. Scott v. Astrue, 529 F.3d 818 (8th Cir. 2008) (remand appropriate where ALJ’s factual findings insufficient to permit appellate substantial-evidence review)
Senne v. Apfel, 198 F.3d 1065 (8th Cir. 1999) (court may decline to set aside administrative finding when record supports overall determination)