Ramona Teague v. Michael J. Astrue, No. 10-2939 (8th Cir. 2011)
Annotate this CasePlaintiff sought disability insurance benefits under the Social Security Act, alleging that migraine headaches, affective mood disorder, and mayofascial back pain left her unable to work. At issue was whether the administrative law judge's ("ALJ") decision was supported by substantial evidence and whether the ALJ properly weighed physicians' opinions in determining plaintiff's residual functional capacity. The court concluded that substantial evidence supported the ALJ's decision to discredit plaintiff's subjective complaints where none of her doctors reported functional or work related limitations due to her headaches and where there was no basis for her creditability. The court also held that the ALJ properly weighed the physicians' opinions in determining plaintiff's residual functional capacity.
Court Description: Civil case - Social Security. ALJ did not err in discrediting claimant's testimony that she was disabled by migraines, as none of her doctors reported functional or work related limitations due to the headaches; ALJ properly weighed medical evidence regarding back pain and mental condition as the doctors' opinions were not consistent with their own notes, tests and observations; the denial of disability benefits was supported by substantial evidence.
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