Albert Rankin v. Kenneth S. Apfel, Commissioner of Social Security

Citations: 195 F.3d 427; 1999 U.S. App. LEXIS 29353; 1999 WL 1012297Docket: 99-1601

Court: Court of Appeals for the Eighth Circuit; November 9, 1999; Federal Appellate Court

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Albert Rankin appealed the denial of his social security disability benefits after an Administrative Law Judge (ALJ) determined he was disabled only until April 3, 1996, due to a work-related neck injury. Rankin contended that he remained unable to work due to severe pain. The ALJ found his complaints credible for the initial period but determined that after April 3, 1996, the objective evidence did not support his claims of disabling pain. The Eighth Circuit Court of Appeals affirmed the lower court's summary judgment in favor of the Commissioner of Social Security, citing substantial evidence supporting the ALJ's conclusion that Rankin's condition had improved, allowing him to perform light work. The court evaluated Rankin's credibility based on various factors, including his daily activities and medical records, ultimately concluding that the evidence did not substantiate his claims post-April 1996. The presence of contrary evidence in the record was insufficient to overturn the Commissioner's decision.

Rankin's daily activities indicate that he does not experience disabling pain. Between 1995 and 1996, he attended ranch management classes for a year and a half, attending hour-long sessions until the curriculum required physically demanding tasks. He also traveled 750 miles by car, stopping every three hours, which contradicts his claims of severe limitations. This evidence supports the Administrative Law Judge (ALJ)'s finding that Rankin's allegations of significant pain are not credible, referencing Melton v. Apfel and Riggins v. Apfel. 

Physical therapy records demonstrate substantial improvement in Rankin's condition, with intermittent attendance during periods of heightened pain. He discontinued therapy on November 11, 1995, having met his goals of pain reduction, strength, and flexibility, although he returned briefly after a car accident in January 1996. His infrequent therapy visits and positive outcomes further undermine his claims of disabling pain, as cited in Harwood v. Apfel and Black v. Apfel.

On April 2, 1996, a functional-capacity assessment by physical therapist Anthony Yurick indicated Rankin could perform an eight-hour workday, with specific capabilities for lifting, sitting, standing, and walking. Although not a physician's opinion, this assessment supports the ALJ's credibility finding, referencing Stephens v. Shalala.

Additionally, Rankin's minimal use of prescription pain medications, opting instead for over-the-counter remedies starting in 1996, provides further evidence supporting the ALJ's credibility determination, as cited in Riggins v. Apfel.

Rankin argues that the Administrative Law Judge (ALJ) improperly discounted the testimony of his treating physician, Dr. Goff, who stated that Rankin was "unable to tolerate" full-time, light-duty work. Typically, a treating physician's opinion holds significant weight; however, Dr. Goff's assessment relies heavily on Rankin's subjective complaints and conflicts with substantial objective evidence, including Rankin's daily activities and physical therapy records. Dr. Goff incorrectly interpreted Rankin's withdrawal from a ranch-management program as evidence of his inability to work, misunderstanding that Rankin left due to difficulties with the program's active components, not because he could not handle sedentary tasks. Consequently, the ALJ appropriately did not grant deference to Dr. Goff's opinion. The District Court concluded that the overall evidence supports Rankin's capability for light work, leading to the affirmation of the summary judgment in favor of the Commissioner.