Eric West-Viotay v. Andrew Saul, No. 19-3648 (8th Cir. 2020)
Annotate this CaseCourt Description: [Per Curiam - Before Colloton, Kelly,and Erickson, Circuit Judges] Civil case - Social Security. Substantial evidence supported the denial of disability benefits; specifically, substantial evidence supported the ALJ's finding that claimant's mental impairments did not meet the "paragraph C" criteria of the applicable mental disorder listing as claimant did not live in a highly structured setting; nor did the ALJ err in determining claimant's Residual Functional Capacity.
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United States Court of Appeals For the Eighth Circuit ___________________________ No. 19-3648 ___________________________ Eric West-Viotay lllllllllllllllllllllPlaintiff - Appellant v. Andrew Saul, Commissioner of Social Security Administration lllllllllllllllllllllDefendant - Appellee ____________ Appeal from United States District Court for the Southern District of Iowa - Davenport ____________ Submitted: October 27, 2020 Filed: November 6, 2020 [Unpublished] ____________ Before COLLOTON, KELLY, and ERICKSON, Circuit Judges. ____________ PER CURIAM. Eric West-Viotay appeals the district court’s1 order affirming the denial of disability insurance benefits and supplemental security income. We review the 1 The Honorable Robert W. Pratt, United States District Judge for the Southern District of Iowa. district court’s judgment de novo, and will affirm unless the Commissioner’s findings are unsupported by substantial evidence or result from legal error. See Twyford v. Comm’r, Soc. Sec. Admin., 929 F.3d 512, 516 (8th Cir. 2019). After consideration of West-Viotay’s arguments for reversal, we agree with the court that substantial evidence in the record as a whole supports the adverse decision. Specifically, we conclude that substantial evidence supports the administrative law judge’s finding that West-Viotay’s mental impairments did not meet the “paragraph C” criteria of the applicable mental disorder listings, as he did not live in a highly structured setting. See Dols v. Saul, 931 F.3d 741, 747 (8th Cir. 2019). Considering the record under the deferential substantial-evidence standard, we also find no error in the ALJ’s findings on residual functional capacity. See Chismarich v. Berryhill, 888 F.3d 978, 980 (8th Cir. 2018) (per curiam). While the RFC findings did not specify workrelated limitations based on some moderate functional-area limitations that the ALJ found under the “paragraph B” criteria, the two findings serve distinct purposes at the separate steps of the sequential evaluation process. See Social Security Ruling 96-8p, 1996 WL 374184, at *4 (Soc. Sec. Admin. July 2, 1996). Here, the findings can be harmonized, as the ALJ adequately explained why greater work-related limitations were not warranted. See Chismarich, 888 F.3d at 980. The judgment is affirmed. ______________________________ -2-
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