News & Information

CCH® UNEMPLOYMENT INSURANCE — 5/19/15

Treating physicians’ opinions properly discounted, says Eighth Circuit

Generally, a treating physician’s opinion should be given controlling weight if it is medically well-supported and is not inconsistent with the other substantial evidence contained in the record. Here, the claimant suffered from a brain injury caused by a 1998 car accident and also a 2004 back injury. Due to his conditions, the claimant sought treatment from a number of physicians. The claimant’s primary care physician estimated that the claimant would miss more than four days of work per month due to his injuries and his chiropractor stated that the claimant was severely limited in his ability to work. In addition, a psychiatric evaluation listed the claimant’s various problems caused by his brain injury. Despite these opinions, the Administrative Law Judge (ALJ) determined that the claimant had the residual functional capacity to perform light work and was, therefore, not entitled to disability benefits. The claimant argued that the ALJ failed to give the appropriate weight to his treating physicians’ opinions and appealed. The court noted that the opinion of a treating physician does not automatically control and the record as a whole still needs to be evaluated. Indeed, a treating physician’s opinion may be discounted or disregarded altogether where other opinions are better supported by the evidence. In this case, the court found that the ALJ sufficiently catalogued the evidence contained in the record that supported the finding that the claimant could perform light work. Further, there was significant evidence contained in the record that was inconsistent with the treating physicians’ opinions. The ALJ gave the appropriate weight to the opinions and the decision to deny benefits was supported by substantial evidence. Therefore, the decision of the district court was affirmed (Charles Gordon Miller v. Colvin, CA-8, No. 14-1639, April 27, 2015).