Willie Boyd, Jr. v. Carolyn W. Colvin
831 F.3d 1015
| 8th Cir. | 2016Background
- Willie Boyd applied for SSI and DIB in October 2011 claiming disability from August 11, 2011 due to diabetes, heart disease, and chronic pain; his claims were denied by an ALJ and the denial was affirmed by the district court.
- Medical records showed long‑standing Type II diabetes, non‑ischemic cardiomyopathy, peripheral neuropathy, and musculoskeletal complaints; consultative and treating notes ranged from mild/moderate functional limits to Dr. Johnson’s 2012 opinion of severe limitations.
- Consultative examiners (Dr. Cobb, Dr. Johnson) documented limited range of motion, paresthesia, decreased reflexes, absent dorsalis pedis pulses, and some edema; however many exams showed no muscle weakness, normal gait/coordination, and intact fine motor tasks.
- A state agency reviewer opined claimant could perform sedentary work with limited standing/walking and limited lifting.
- At hearing, Boyd (age 44) testified to severe, daily pain, urinary urgency, limited mobility, and inability to perform fine hand tasks; a vocational expert testified that an individual with the ALJ’s RFC could perform significant numbers of unskilled sedentary jobs nationally.
- The ALJ found Boyd could perform sedentary work with only occasional postural activities, rejected Dr. Johnson’s extreme limitations and portions of claimant’s testimony as not supported by objective findings, and concluded jobs exist that Boyd can perform; the Eighth Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ’s RFC omitted limitations from left‑shoulder, handling/fingering, and decreased upper‑extremity reflexes | Boyd: ALJ failed to include lifting, carrying, reaching, handling, and fingering limits supported by exams and Dr. Johnson’s opinion | Commissioner: ALJ permissibly discounted extreme limitations as unsupported by clinical findings and relied on other medical evidence and state‑agency assessment | Affirmed — ALJ’s RFC supported by substantial evidence; inconsistency in exam findings justified discounting Dr. Johnson’s extreme restrictions |
| Whether ALJ erred in discounting claimant’s subjective complaints and activities evidence | Boyd: ALJ improperly rejected credible testimony and daily‑activity limitations supporting disability | Commissioner: ALJ provided valid reasons — inconsistencies with medical evidence, lack of objective support, and absence of treating physician restrictions | Affirmed — ALJ gave adequate, legally sufficient reasons to discount claimant’s testimony |
| Whether VE testimony established significant numbers of jobs given the RFC | Boyd: VE gave category numbers and examples; unclear that numbers correspond to sedentary jobs the RFC allows | Commissioner: VE explicitly testified the numbers were for unskilled sedentary jobs that matched the RFC | Affirmed — VE testimony constituted substantial evidence that significant jobs exist in national economy |
| Whether ALJ properly weighed medical opinions | Boyd: ALJ undervalued consultative opinions that found severe limitations | Commissioner: ALJ reasonably weighed older and inconsistent opinions and is responsible for RFC determination | Affirmed — ALJ properly evaluated and rejected inconsistently supported opinions; RFC determination for ALJ to make |
Key Cases Cited
- Anderson v. Astrue, 696 F.3d 790 (8th Cir. 2012) (standard of de novo review of district court affirming ALJ)
- Jones v. Astrue, 619 F.3d 963 (8th Cir. 2010) (definition of substantial evidence)
- Moore v. Astrue, 572 F.3d 520 (8th Cir. 2009) (RFC based on all relevant evidence and is ALJ’s responsibility)
- Davidson v. Astrue, 501 F.3d 987 (8th Cir. 2007) (treatment‑notes/opinion inconsistencies support rejecting physician opinion)
- Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984) (factors for evaluating claimant credibility)
- Martise v. Astrue, 641 F.3d 909 (8th Cir. 2011) (hypothetical to VE must include impairments ALJ finds credible; VE testimony can constitute substantial evidence)
- Dipple v. Astrue, 601 F.3d 833 (8th Cir. 2010) (Commissioner bears burden to show significant numbers of jobs exist)