Combs v. Berryhill, No. 16-2849 (8th Cir. 2017)
Annotate this CaseThe Eighth Circuit reversed the district court's order affirming the ALJ's denial of plaintiff's application for disability insurance benefits and supplemental security income. The court held that the ALJ erred in relying on his own inferences about what plaintiff's medical providers meant when they noted in her medical records that she was in "no acute distress" and had "normal movement of all extremities" to determine her residual functioning capacity. The court explained that remand was necessary so the ALJ may conduct further inquiry as to what relevance plaintiff's being in "no acute distress" and having "normal movement of all extremities" has in terms of plaintiff's ability to function in the workplace.
Court Description: Kelly, Author, with Smith, Chief Judge, and Sippel, District Judge. Civil case - Social Security. There was no opinion from the treating physicians on the crucial issue of whether claimant was limited to sedentary work or could perform light work, and the ALJ erred in relying on his own inferences about what the medical providers meant when they noted in claimant's medical records that claimant was not in acute distress and had normal movement of her extremities; by relying on his own inferences and failing to seek clarification from claimant's medical providers, the ALJ failed to satisfy his duty to fully and fairly develop the record; remanded for further proceedings. Chief Judge Smith, dissenting.
The court issued a subsequent related opinion or order on December 28, 2017.
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