Travis Chaney v. Carolyn W. Colvin
812 F.3d 672
| 8th Cir. | 2016Background
- Travis Chaney applied for Title II and XVI disability benefits, alleging onset initially in 2003 (later amended to Jan 1, 2004), based primarily on chronic low back pain, obesity, hypertension, mood/anxiety disorder, and substance use.
- Two ALJ hearings were held (2008, 2011) after an initial decision and a district-court remand; the second ALJ found severe impairments but determined Chaney was less-than-fully credible and had an RFC for limited light, unskilled work.
- The ALJ discounted treating-physician opinions and third-party statements partly because Chaney misreported or concealed illegal drug use, was noncompliant with treatment/medication, and engaged in activities inconsistent with claimed limitations.
- The Appeals Council denied review of the second ALJ decision; the district court affirmed the denial of benefits, finding any ALJ errors harmless and the decision supported by substantial evidence.
- The Eighth Circuit reviewed de novo and affirmed, concluding (1) the ALJ’s credibility findings were supported by substantial evidence, (2) the RFC accounted for medication effects, and (3) treating opinions were properly discounted where inconsistent with the record and incomplete due to nondisclosure of drug use.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credibility determination | Chaney: ALJ made factual errors and drew improper inferences (e.g., motive to seek benefits, medication misstatements) that undermined credibility finding | Commissioner: ALJ’s credibility finding rests on multiple valid inconsistencies (activities, drug/medication misuse, therapist/consultative impressions) | Affirmed — ALJ’s credibility discount supported by substantial evidence despite some factual errors |
| Consideration of medications and third-party observations | Chaney: ALJ failed to consider medication strength/side effects and ignored Byrd’s letter documenting pain during massage courses | Commissioner: ALJ limited work for medication effects and admitted Byrd’s letter into the record; even if not discussed, record supports RFC for light unskilled work | Affirmed — RFC adequately accounted for medication effects; Byrd’s letter would not require a different RFC |
| Weight given to treating physicians’ opinions | Chaney: ALJ erred by not giving controlling weight to Drs. Walker and Wooten questionnaires | Commissioner: Treating opinions were inconsistent with other record evidence and lacked information about Chaney’s drug use/noncompliance, so not controlling | Affirmed — ALJ permissibly discounted treating opinions as inconsistent and based on incomplete information |
Key Cases Cited
- Byes v. Astrue, 687 F.3d 913 (8th Cir. 2012) (standard of review for appeals of denial of benefits)
- Pelkey v. Barnhart, 433 F.3d 575 (8th Cir. 2006) (substantial evidence standard)
- Milam v. Colvin, 794 F.3d 978 (8th Cir. 2015) (consider evidence supporting and detracting from ALJ)
- Dixon v. Barnhart, 353 F.3d 602 (8th Cir. 2003) (when two inconsistent positions possible, court defers to Commissioner)
- Edwards v. Barnhart, 314 F.3d 964 (8th Cir. 2003) (credibility primarily for ALJ)
- Goff v. Barnhart, 421 F.3d 785 (8th Cir. 2005) (ALJ may disbelieve subjective complaints when record inconsistent)
- Anderson v. Barnhart, 344 F.3d 809 (8th Cir. 2003) (medication misuse is valid factor in credibility determinations)
- Craig v. Apfel, 212 F.3d 433 (8th Cir. 2000) (ALJ must fully and fairly develop the record)
- Turpin v. Colvin, 750 F.3d 989 (8th Cir. 2014) (treating physician opinions evaluated in context of whole record)
- Wildman v. Astrue, 596 F.3d 959 (8th Cir. 2010) (noncompliance can undermine treating physician’s opinion)