Debra Sparks v. Carolyn W. Colvin, No. 14-2325 (8th Cir. 2015)
Annotate this CaseCourt Description: Civil case - Social Security. The doctrine of collateral estoppel precluded claimant from relitigating whether her mental impairment met Listing 12.05C; substantial evidence on the record as a whole supported the ALJ's findings regarding the credibility of claimant's subjective complaints and the severity of her impairments.
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United States Court of Appeals For the Eighth Circuit ___________________________ No. 14-2325 ___________________________ Debra Sparks, lllllllllllllllllllll Plaintiff - Appellant, v. Carolyn W. Colvin, Acting Commissioner of Social Security, lllllllllllllllllllll Defendant - Appellee. ____________ Appeal from United States District Court for the Western District of Arkansas - Harrison ____________ Submitted: February 20, 2015 Filed: March 5, 2015 [Unpublished] ____________ Before LOKEN, COLLOTON, and KELLY, Circuit Judges. ____________ PER CURIAM. Debra Sparks appeals the district court’s1 order affirming the denial of disability insurance benefits and supplemental security income. For reversal, Sparks argues that the Administrative Law Judge (ALJ) erred in his determination, because he failed to find that (1) her severe impairments included borderline intellectual functioning and (2) her mental impairment met Listing 12.05C. Following careful review of the parties’ submissions and the record before us, we conclude that the doctrine of collateral estoppel precludes Sparks from relitigating whether her mental impairment met Listing 12.05C. See Hardy v. Chater, 64 F.3d 405, 407 (8th Cir. 1995). We further conclude that substantial evidence in the record as a whole supports the ALJ’s findings regarding the credibility of Sparks’s subjective complaints, and the severity of her impairments. Accordingly, we affirm the district court’s judgment. See 8th Cir. R. 47B. ______________________________ 1 The Honorable Erin L. Setser, United States Magistrate Judge for the Western District of Arkansas, to whom the case was referred for final disposition by consent of the parties pursuant to 28 U.S.C. § 636(c). -2-
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