Bradshaw v. Heckler

Summary

The Eighth Circuit held that the administrative law judge improperly allocated the burden of proof after the claimant established that his hip impairment prevented him from performing his past work. The court also held that the medical-vocational guidelines could not be used without vocational-expert testimony because pain constituted a nonexertional impairment. The court reversed the district court and remanded for a rehearing.

Holdings

1. Once a claimant proves that a severe impairment prevents performance of past relevant work, the burden shifts to the Secretary to prove that the claimant is not disabled and can perform other work available in the national economy. Because the administrative law judge failed to properly allocate that burden, reversal and remand were required where the outcome might have differed under the correct allocation.
2. A treating physician's recommendation that a claimant obtain retraining for nonmanual work, without more, does not constitute substantial evidence that the claimant can perform sedentary work, particularly where the physician also stated that prolonged sitting increased the claimant's discomfort.
3. When a claimant suffers from a nonexertional impairment that affects the ability to perform work, the medical-vocational guidelines are not controlling and cannot alone direct a finding of disabled or not disabled; vocational-expert testimony or other evidence is required unless the nonexertional impairment does not significantly limit the relevant occupational base.

Questions Presented

1. Whether the administrative law judge improperly placed on Bradshaw the burden of proving that he was unable to perform sedentary work after Bradshaw established that his severe impairment prevented him from performing his past relevant work.
2. Whether the Secretary's finding that Bradshaw could perform sedentary work was supported by substantial evidence.
3. Whether the administrative law judge could rely on the medical-vocational guidelines without vocational-expert testimony where pain constituted a nonexertional impairment affecting Bradshaw's ability to perform sedentary work.

Disposition

reversed_and_remanded