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U.S. Court of Appeals for the Eighth Circuit, 2010 Eighth Circuit affirmed denial of disability insurance benefits to claimant alleging disability from degenerative joint disease, anxiety, and bipolar disorder, finding ALJ properly discounted treating providers' opinions and substantially supported mental residual functional capacity findings.

Eighth Circuit affirmed denial of disability insurance benefits to claimant alleging disability from degenerative joint disease, anxiety, and bipolar disorder, finding ALJ properly discounted treating providers' opinions and substantially supported mental residual functional capacity findings.

Quet Sledge v. Michael J. Astrue
U.S. Court of Appeals for the Eighth Circuit · Decided February 5, 2010 · Bye, Per Curiam, Riley, Shepherd
364 F. App'x 307

Outcome: Affirmed for appellee.

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Counsel

James H. Green, Kansas City, MO, for appellant., Mark S. Naggi, Spec. Asst. U.S. Atty., Kansas City, MO (Matt J. Whitworth, Acting U.S. Atty., on the brief), for appellee; Kristi A. Schmidt, Chief Counsel, Region VII, Social Sec. Admin., Kansas City, MO, of counsel.

Quet Sledge v. Michael J. Astrue

What happened

The facts of the case, in plain language.

Sledge alleged disability since January 2005 from degenerative joint disease, anxiety, and a bipolar disorder.

The ALJ determined that Sledge had engaged in substantial gainful activity until at least March 31, 2005.

Sledge's combined physical and mental impairments were severe but did not meet or equal the requirements of any listing.

Based on a vocational expert's response to the ALJ's hypothetical, Sledge's mental and physical residual functional capacity did not preclude her past relevant work as a data-entry worker, and she could perform specified unskilled sedentary jobs.

The ALJ gave good reasons for discounting the low global assessment of functioning ratings provided by Sledge's treating mental health providers.

What the court decided

Quet Sledge appealed the denial of Social Security disability insurance benefits for disabilities allegedly occurring since January 2005, including degenerative joint disease, anxiety, and bipolar disorder. An administrative law judge found that Sledge had engaged in substantial gainful activity until March 31, 2005, that her impairments were severe but did not meet regulatory listings, that her subjective complaints lacked complete credibility, and that she could perform her past work as a data-entry worker and other unskilled sedentary jobs. The district court summarily affirmed. On de novo review, the Eighth Circuit affirmed, holding that the ALJ properly discounted the low global assessment of functioning ratings provided by Sledge's treating mental health providers and that the ALJ's residual functional capacity findings were supported by substantial evidence in the record.

  1. An ALJ may discount global-assessment-of-functioning ratings provided by treating mental health providers when the ALJ articulates good reasons grounded in the record as a whole, including the provider's own inconsistency or inconsistency with other substantial evidence. (*308)
  2. An ALJ's mental residual functional capacity findings are upheld when supported by substantial evidence on the record as a whole, including medical records, treating physician observations, and the claimant's own description of her limitations. (*308)

How the court reached its decision

The court's reasoning, step by step.

Whether the ALJ properly discounted the low global-assessment-of-functioning ratings assigned by Sledge's treating mental health providers. The ALJ gave good reasons for discounting the low GAF ratings of Sledge's treating mental health providers, consistent with the rule permitting an ALJ to decline controlling weight when the record as a whole does not support the opinion. The ALJ properly discounted the treating mental health providers' GAF ratings.

Whether the ALJ's mental residual functional capacity findings are supported by substantial evidence on the record as a whole. The ALJ's mental RFC findings were informed by a vocational expert's response to a hypothetical accounting for Sledge's mental and physical limitations, along with broader record evidence; the properly discounted GAF ratings did not undermine those findings. The ALJ's mental RFC findings are supported by substantial evidence on the record as a whole.

Key quotes from the opinion

Notable passages from the opinion, in the court's own words.

“Sledge alleged disability since January 2005 from degenerative joint disease, anxiety, and a bipolar disorder.”
Factual background of claimant's disability claims — *308
“the ALJ gave good reasons for discounting the low global-assessment-of-functioning ratings of Sledge's treating mental health providers”
Court sustains ALJ's discount of treating provider GAF ratings — *308
“the ALJ's mental RFC findings are supported by substantial evidence on the record as a whole”
RFC findings meet substantial evidence standard — *308
“Following de novo review of the record, see Davidson v. Astrue, 578 F.3d 838, 841-42 (8th Cir. 2009), we affirm.”
Standard of review and affirmance — *308

Cases the court relied on

Earlier decisions the court cited as authority for its ruling.

  • Davidson v. Astrue (578 F.3d 838 (8th Cir. 2009)) — Establishes the de novo standard for Eighth Circuit review of district court affirmances of Social Security ALJ decisions and articulates the requirement that RFC determinations be grounded in all relevant evidence.
  • Hacker v. Barnhart (459 F.3d 934 (8th Cir. 2006)) — Supplies the rule governing when an ALJ may decline to give controlling weight to a treating physician's opinion, including where the opinion is unsupported by medically acceptable techniques, inconsistent with substantial evidence, or undermined by the physician's own inconsistency.

Cases that cite this one

536 later published cases cite this decision. The 9 that cite it most often are listed here.

This list shows which later cases cite this one. It does not say how they treated it, and no review of that has been done. Not a substitute for Shepard’s or KeyCite — verify before relying.

Full opinion

The complete text of the court's opinion as published.

Opinion

PER CURIAM.

Quet Sledge appeals the district court’s 1 order affirming the denial of disability insurance benefits. Sledge alleged disability since January 2005 from degenerative joint disease, anxiety, and a bipolar disorder. After a September 2007 hearing, where Sledge was counseled, an administrative law judge (ALJ) determined that Sledge had engaged in substantial gainful activity until at least March 31, 2005; that her combined physical and mental impairments were severe, but alone or combined, they did not meet or equal the requirements of any listing; that her subjective complaints were not entirely credible; and that based on a vocational expert’s response to the ALJ’s hypothetical, Sledge’s mental residual functional capacity (RFC) and physical RFC did not preclude her past relevant work as a data-entry worker, and further, *308 she could perform specified unskilled sedentary jobs existing in substantial numbers. The Appeals Council denied review, and the district court summarily affirmed. Following de novo review of the record, see Davidson v. Astrue, 578 F.3d 838, 841-42 (8th Cir. 2009), we affirm.

Contrary to Sledge’s primary assertions of error, we conclude that the ALJ gave good reasons for discounting the low global-assessment-of-functioning ratings of Sledge’s treating mental health providers. See Hacker v. Barnhart, 459 F.3d 934, 937 (8th Cir. 2006) (ALJ may elect in certain circumstances not to give controlling weight to treating physician’s opinion, as record must be evaluated as whole; for treating physician’s opinion to have controlling weight, it must be supported by medically acceptable diagnostic techniques and not be inconsistent with other substantial evidence in case record; physician’s own inconsistency may diminish or eliminate weight accorded to his opinion). We also conclude that the ALJ’s mental RFC findings are supported by substantial evidence on the record as a whole. See Davidson, 578 F.3d at 844 (ALJ should determine RFC based on all relevant evidence, including medical records, observations of treating physicians and others, and claimant’s own description of her limitations). We reject as meritless Sledge’s other arguments for reversal. Accordingly, we affirm.

1

. The Honorable Fernando J. Gaitan, Chief Judge, United States District Court for the Western District of Missouri.

Continue your research

  • Eighth Circuit cases applying the treating-physician rule to GAF ratings in Social Security disability appeals
  • Cases citing Hacker v. Barnhart on treating physician opinion weight post-2006
  • Secondary sources on the evidentiary value of GAF scores in Social Security mental impairment adjudications
This page includes AI-generated summaries and analysis based on the full opinion text and citing cases. We believe the summaries are accurate, but you should always verify the holdings, quotes, and treatment data against the original opinion before relying on them in legal proceedings.

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