Rita Jarmon v. Kilolo Kijakazi, No. 22-2619 (8th Cir. 2023)
Annotate this CaseCourt Description: [Per Curiam - Before Loken, Kelly, and Kobes, Circuit Judges] Civil case - Social Security. The ALJ properly applied 20 C.F.R. Sec. 404.1520c which explicitly abrogates the treating source rule; substantial evidence supported the denial of benefits. [ March 06, 2023 ]
Download PDF
United States Court of Appeals For the Eighth Circuit ___________________________ No. 22-2619 ___________________________ Rita Jarmon lllllllllllllllllllllPlaintiff - Appellant v. Kilolo Kijakazi, Acting Commissioner of Social Security Administration lllllllllllllllllllllDefendant - Appellee ____________ Appeal from United States District Court for the Eastern District of Arkansas - Central ____________ Submitted: March 1, 2023 Filed: March 7, 2023 [Unpublished] ____________ Before LOKEN, KELLY, and KOBES, Circuit Judges. ____________ PER CURIAM. Rita Jarmon appeals the district court’s1 order affirming the denial of disability insurance benefits. Jarmon argues that the administrative law judge (ALJ) erred in evaluating the opinion of her one-time treating physician under 20 C.F.R. § 404.1520c. We find that the ALJ properly evaluated the opinion, as that regulation applies to claims--like Jarmon’s--filed after March 27, 2017, and explicitly abrogates the treating source rule; and as the ALJ considered the supportability and consistency of the opinion. See Austin v. Kijakazi, 52 F.4th 723, 728-30 (8th Cir. 2022) (under revised regulations, treating physicians’ opinions are no longer entitled to special deference; finding that prior precedent applying treating-source rule was inapposite, and that ALJ adequately analyzed opinion by addressing its supportability and consistency). Thus, we find that substantial evidence in the record as a whole supports the ALJ’s adverse decision. See Kraus v. Saul, 988 F.3d 1019, 1023-24 (8th Cir. 2021) (standard of review). The judgment is affirmed. ______________________________ 1 The Honorable Brian S. Miller, United States District Judge for the Eastern District of Arkansas, adopting the report and recommendations of the Honorable Joe J. Volpe, United States Magistrate Judge for the Eastern District of Arkansas. -2-
Some case metadata and case summaries were written with the help of AI, which can produce inaccuracies. You should read the full case before relying on it for legal research purposes.
This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply.
