Melissa Galloway v. Kilolo Kijakazi, No. 21-3691 (8th Cir. 2022)
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Plaintiff appealed from the district court’s judgment upholding the Social Security Commissioner’s denial of her application for social security disability insurance benefits. She argues that the administrative law judge (ALJ) believed that she lacked the ability to follow detailed instructions, but failed to include that limitation in the hypothetical question posed to the vocational expert or in the residual functional capacity finding. Plaintiff also contends that the ALJ failed to adequately explain why only partial weight was given to the opinions of her treating mental health providers.
The Eighth Circuit affirmed. The court considered the fact that the ALJ had found earlier in the decision that Plaintiff had only a moderate limitation in understanding, remembering, and applying information. The sentence could thus be read as finding the opinion “not necessarily pertinent,” because the ALJ was not giving controlling weight to the providers’ opinion and because Plaintiff’s moderate limitations were accounted for in the hypothetical question and the residual functional capacity determination.
Further, the court found to be unpersuasive Plaintiff’s alternative argument that the ALJ failed to adequately explain why she gave only partial weight to the testimony of Plaintiff’s mental health providers- a licensed independent social worker and an advanced registered nurse practitioner. Under the regulations, neither mental health provider is considered an acceptable medical source whose opinion may be afforded controlling weight. Moreover, their opinion was “entitled to relatively little evidentiary value” because it was “rendered on a check-box and fill-in-the-blank form.” Thus, the court concluded that substantial evidence supported the ALJ’s denial of benefits.
Court Description: [Wollman, Author, with Colloton and Shepherd, Circuit Judges] Civil case - Social Security. Claim that there was conflict between the ALJ's hypothetical question and the residual functional capacity determination rejected; no error in giving only partial weight to the joint opinion of claimant's mental health providers as they did not cite objective findings to support their conclusions and their progress notes were not fully consistent with their written opinion; substantial evidence supported the denial of benefits. [ August 17, 2022 ]
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