Whitman v. Colvin, No. 13-2215 (8th Cir. 2014)
Annotate this CasePlaintiff appealed the denial of disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. 401-434. The court agreed with the district court that the ALJ properly articulated his reasons for granting little weight to plaintiff's physician's opinions, and for finding the physician's opinions to be inconsistent with the record as a whole; that the ALJ properly considered plaintiff's medical records, observations of treating physicians, and plaintiff's own description of his limitations in making the residual functional capacity (RFC) assessment for plaintiff; and that the ALJ made a proper RFC determination based on a fully and fairly developed record. The court also concluded that substantial evidence exists in the record to support the ALJ's adverse credibility finding, and the district court did not abuse its discretion by failing to remand for reconsideration under 42 U.S.C. 405(g). Accordingly, the court affirmed the judgment of the district court.
Court Description: Social Security - disability insurance benefits. Decision to deny benefits is supported by substantial evidence, as ALJ properly articulated reasons for discounting physician's opinions; ALJ properly considered the medical records, observations, and Whitman's own descriptions of his limitations; and decision was based on a fully and fairly developed record. Record supports ALJ's adverse credibility finding. District court did not abuse its discretion in denying motion to remand to consider new evidence, as evidence was partially cumulative and not probative of the applicable time period and Whitman did not show good cause for failing to include evidence into the record.
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