Grindley v. Kijakazi, No. 20-1946 (8th Cir. 2021)
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The Eighth Circuit affirmed the district court's order affirming the Social Security Administration's denial of plaintiff's claim for disability benefits. Plaintiff filed a claim for a period of disability, disability insurance benefits, and supplemental security income based on her diagnoses of mood disorders, lupus, and fibromyalgia, among other ailments.
The court concluded that substantial evidence in the record supported the ALJ's denial of plaintiff's claim for benefits. In this case, the ALJ did not err by relying exclusively on the lack of objective evidence supporting plaintiff's fibromyalgia diagnosis to deny benefits. Rather, the ALJ noted that objective findings did not support her subjective allegations of disabling symptoms. Likewise, the court rejected plaintiff's claims that the ALJ erred in disregarding evidence of her moderate-severe musculoskeletal pain and widespread arthralgia, as well as the multidimensional health assessment questionnaire indicating that she had difficulty performing daily tasks. The court explained that there was substantial evidence in the record for the ALJ to focus on the "normal" reports and findings by plaintiff's treating physicians. Even if the ALJ made some misstatements in his order, the errors were harmless.
The court also concluded that the district court did not err in failing to develop the record to clarify the number of tender points where any inconsistences were harmless error. The court further concluded that the ALJ's credibility determination and weight assigned to the testimony was supported by undisputed facts that plaintiff suffered from addiction, smoked, and failed to follow her treatment advice. Finally, the ALJ properly considered plaintiff's allegations of pain and properly weighed the decisions of her treating physicians and state agency consultant's opinions.
Court Description: [Grasz, Author, with Chief Judge Smith and Shepherd, Circuit Judges] Civil Case - Social Security. In appeal from the denial of social security benefits, the ALJ did not err by relying exclusively on the lack of objective evidence supporting her fibromyalgia diagnosis to deny benefits, but instead noted the objective findings did not support her subjective allegations of disabling symptoms; the ALJ did not err in disregarding certain outlier results evidence over more consistent "normal" results. Any factual misstatements were harmless. The district court did not err in failing to develop the record to clarify the number of tender points, as any inconsistences were harmless error. The ALJ's credibility determination and weight assigned to the testimony was supported by undisputed facts that Grindley suffered from addiction, smoked, and failed to follow her treatment advice. The ALJ properly considered Grindley's allegations of pain and properly weighed the decisions of her treating physicians and state agency consultant's opinions.
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