Lisa Austin v. Kilolo Kijakazi, No. 22-1617 (8th Cir. 2022)
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Plaintiff appealed the district court’s1 order upholding the Commissioner of the Social Security Administration’s (Commissioner) denial of Social Security disability insurance benefits, arguing that the Commissioner’s decision was not supported by substantial evidence. Plaintiff challenged two aspects of the Commissioner’s decision. First, Plaintiff argued that the ALJ committed legal error by improperly evaluating the medical evidence. Second, Plaintiff argued that the ALJ’s RFC assessment was unsupported by substantial evidence.
The Eighth Circuit affirmed. The court explained that the ALJ found that Plaintiff had the RFC to “perform light work . . . ; except, she should avoid extreme cold and wetness, avoid work in direct sunlight, and avoid loud noises.” Central to this finding was the ALJ’s conclusion that Plaintiff’s surgically implanted neurostimulator resulted in “on-going symptom control without a consistent description of debilitating pain or the inability to function.” A lack of evidence of treatment in the months prior to the hearing undermines Plaintiff’s claim of disabling headaches. The court ultimately concluded that the ALJ’s RFC assessment is within the “available zone of choice” provided by the whole record.
Court Description: [Shepherd, Author, with Gruender and Erickson, Circuit Judges] Civil case - Social Security. The ALJ did not improperly evaluate the medical evidence in reaching the decision to deny benefits as the ALJ adequately evaluated the persuasiveness of the doctor's opinion and had sufficient grounds to conclude the opinion was unpersuasive; the ALJ also properly evaluated the persuasiveness of a second doctor's opinion; substantial evidence supported the ALJ's residual functional capacity assessment.
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