Schwandt v. Berryhill, No. 17-3406 (8th Cir. 2019)
Annotate this CaseThe Eighth Circuit affirmed the denial of disability insurance benefits to claimant. The court held that the agency was justified in reopening claimant's case based on new and material information; there was no due process violation and claimant had adequate notice that the reopened proceedings could result in a determination that she was not disabled; res judicata did not bar the Commissioner from revising a determination; substantial evidence supported the ALJ's determination that claimant was not disabled from 2012 onward; claims of witness and evidentiary errors rejected; the ALJ did not err in determining that claimant could perform her past relevant work; and there was no error in the ALJ's statement regarding claimant's residual functional capacity (RFC) to the vocational expert where substantial evidence supported the omission of certain limitations from her RFC.
Court Description: Colloton, Author, with Shepherd and Stras, Circuit Judges] Civil case - Social Security. The agency was justified in reopening claimant's case based on new, material information which had a reasonable probability of permitting claimant to retain certain contested benefits; claimant had adequate notice that the reopened proceedings could result in a determination that she was not disabled; claims that the agency was barred from reconsidering the original benefits award by res judicata or the "clean hands" doctrine rejected; the ALJ's determination that claimant was not disabled from 2012 onward was supported by substantial evidence; the ALJ did not err in rejecting certain medical evidence as not supported by the record and did not err in discounting claimant's credibility; statements of lay witnesses were not consistent with claimant's reported daily activities, and the ALJ did not err in discounting them; the ALJ did not err in determining that claimant could perform her past relevant work as a dental hygienist; ALJ's statement of claimant's residual functional capacity to the vocational expert comported with the evidence.
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