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EATON v. KIJAKAZI (2021)

United States Court of Appeals, Eighth Circuit.2021-07-23No. No. 20-2932

Summary

Holding. The court affirmed the district court's judgment upholding the denial of benefits, concluding that substantial evidence in the record supported the ALJ's findings regarding both the medical listing determination and the functional capacity assessment.

Christina Eaton appealed a district court decision upholding the denial of her disability insurance benefits and supplemental security income. The appellate court reviewed whether substantial evidence supported the administrative law judge's (ALJ) decision and found it did. The court determined that the record adequately supported the ALJ's conclusion that Eaton's mental health conditions did not satisfy the relevant regulatory listings and that the ALJ's assessment of her functional capacity was reasonable based on the evidence, including treatment records and her reported daily activities.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether mental health impairments satisfied disability listings
  • Sufficiency of evidence supporting residual functional capacity determination
  • Whether ALJ erred by failing to recontact medical expert after hearing

Procedural posture

Eaton appealed the district court's affirmance of the Social Security Administration's denial of disability insurance benefits and supplemental security income.

Authorities cited

No cited authorities resolved to law.co cases yet.

Opinion

[Unpublished]

Christina Eaton appeals the district courts

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order affirming the denial of disability insurance benefits and supplemental security income. We agree with the court that substantial evidence in the record as a whole supports the adverse decision. See Twyford v. Commr, Soc. Sec. Admin., 929 F.3d 512, 516 (8th Cir. 2019) (de novo review of district courts judgment; this court will affirm unless Commissioners findings are unsupported by substantial evidence or result from legal error). Specifically, we conclude the record supports the administrative law judges (ALJs) finding that Eatons impairments did not meet the mental disorder listings, see id. at 517 (ALJs finding that listing was not met was supported by treatment notes and claimants daily activities); and the ALJs determination of Eatons residual functional capacity (RFC), see Wildman v. Astrue, 596 F.3d 959, 969 (8th Cir. 2010) (ALJ did not err in failing to include limitation in RFC, as he determined that claimants allegations about such limitation were not credible). We find no merit to Eatons argument that the ALJ erred by failing to recontact the medical expert after the hearing. See Onstad v. Shalala, 999 F.2d 1232, 1234 (8th Cir. 1993) (reversal due to failure to develop record is only warranted where such failure is unfair or prejudicial; no prejudice where claimant did not show that evidence ALJ failed to obtain would have made difference in case).

The judgment is affirmed.

FOOTNOTES

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.   The Honorable John T. Maughmer, United States Magistrate Judge for the Western District of Missouri, to whom the case was referred for final disposition by consent of the parties pursuant to 28 U.S.C. § 636(c).

PER CURIAM.