Development of record by ALJ was sufficient says Eighth Circuit
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Tuesday, August 18, 2020

Development of record by ALJ was sufficient says Eighth Circuit

By Payroll and Entitlements Editorial Staff

In this case, the claimant argued that the ALJ improperly weighed the opinions of two medical professionals. The court noted that interpretation of physicians’ findings is a matter of fact left to the ALJ’s authority. In determining that the claimant was not disabled, the ALJ assigned partial weight to the opinion of a consulting examiner and little weight to the opinion of a physician assistant. The court concluded that the ALJ gave sufficient reasons for the weight assigned to the opinions. First, other examiners found no support for the physician’s opinion and he examined the claimant only once. In addition, the physician’s opinion was inconsistent with his medical observations that the claimant had no pain, no abnormality in his joints, and full strength in his arms and legs. The physician assistant completed a checklist with little commentary and, therefore, the opinion possessed little evidentiary value. Finally, the hypothetical posed to the vocational expert sufficiently described the claimant’s cognitive limitations. Although the hypothetical question did not specifically mention the claimant’s reading comprehension test results, it captured the concrete consequences of his impairments. The ALJ’s determinations were based on substantial evidence so the denial of benefits was affirmed (Thomas Hilliard v. Commr., CA-8, No. 19-1169, July 9, 2020).

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