Ingram v. Barnhart

No. 01-3824 (8th Cir. Sept. 10, 2002); No. 96-2533 (8th Cir. Feb. 25, 1997) ; Clearinghouse Number: 52206

Description

Eighth Circuit Articulates Proper Legal Standard for Consideration of Disability Claim Based on Obesity

Abstract

The Eighth Circuit has reversed the district court’s order affirming the denial of disability benefits to appellant claimant and remanded appellant’s claim for reconsideration in light of the proper legal standard. Claimant, a woman in her late forties, alleged disability due to obesity, back and leg pain, and migraine headaches. Finding that claimant had the residual functional capacity to perform work-related activities, the ALJ denied her claim for social security and supplemental security income benefits. The district court affirmed the denial of benefits, and claimant appealed. The court of appeals found that, under the applicable regulation, in order to prove disability based on obesity, claimant is required to establish a history of pain and limitation of motion in any weight-bearing joint or the lumbosacral spine associated with findings of arthritis in the affected joint or spine. The court concluded that, by its plain language, the regulation requires only a history of pain and limitation of motion, and not that a particular level of pain or limitation be demonstrated. The court also held that claimant is not required to show that her symptoms of pain and limitation of motion are caused by arthritis and not just by her obesity. Noting that the record regarding limitation of motion in claimant’s spine is unclear and that x-ray evidence of arthritis in claimant’s knees exists, the court remanded the claim to the ALJ for reconsideration in light of the proper legal standard.

Additional Information

Attorney Information
Docket Date
2002-09-10 00:00:00+00:00

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