Specifically, the Court agreed with Plaintiff that to discontinue her benefits, the Commissioner had a duty to follow the “sequential analysis prescribed in 20 C.F.R. § 404.1594(f)” and that the ALJ's failure to do so amounted to legal error. Id. at *3 (citing Delph v. Astrue, 538 F.3d 940, 945 (8th Cir. 2008)), *8 (quoting Lucas v. Saul, 960 F.3d 1066, 1069 (8th Cir. 2020)). The Court explained that it is the Commissioner's burden at step three of that sequential analysis to “demonstrate that the conditions which previously rendered the claimant disabled have ameliorated, and that the improvement in the physical condition is related to the claimant's ability to work” if they intend to discontinue a claimant's benefits.
“The continuing disability review process involves a sequential analysis prescribed in 20 C.F.R. § 404.1594(f).” Delph v. Astrue, 538 F.3d 940, 945 (8th Cir. 2008) (citation omitted). Although Plaintiff bears the initial burden to demonstrate that she is disabled, once she has done so, the burden shifts to the Commissioner to show that she is no longer disabled based on medical improvement.
Rather, "[w]e must consider evidence in the record that fairly detracts from, as well as supports, the ALJ's decision." Delph v. Astrue , 538 F.3d 940, 945 (8th Cir. 2008). However, we will not reverse the Commissioner's decision merely because we find that "substantial evidence exists in the record that would have supported a contrary outcome."
Rather, "[w]e must consider evidence in the record that fairly detracts from, as well as supports, the ALJ's decision." Delph v. Astrue, 538 F.3d 940, 945 (8th Cir. 2008). However, we will not reverse the Commissioner's decision merely because we find that "substantial evidence exists in the record that would have supported a contrary outcome."
” Delph v. Astrue, 538 F.3d 940, 945 (8th Cir. 2008). The regulations define “medical improvement” as:
The Commissioner may terminate benefits to a person previously adjudged to be disabled upon substantial evidence that the individual's condition has improved "to the point where he is able to perform substantial gainful activity." Delph v. Astrue, 538 F.3d 940, 945 (8th Cir. 2008). The regulations define "medical improvement" as:
The Commissioner may terminate benefits to a person previously adjudged to be disabled upon substantial evidence that the individual's condition has improved “to the point where he is able to perform substantial gainful activity.” Delph v. Astrue, 538 F.3d 940, 945 (8th Cir. 2008). The regulations define “medical improvement” as:
If the Commissioner seeks to end disability benefits because of an improvement in the claimant's medical condition, the Commissioner must demonstrate that "the conditions which previously rendered the claimant disabled have ameliorated, and the improvement in the physical condition is related to claimant's ability to work." Id. (citing 20 C.F.R. 404.1594(b)(2)-(5)); see Delph v. Astrue, 538 F.3d 940, 945 (8th Cir. 2008)("When benefits have been denied based on a determination that a claimant's disability has ceased, the issue is whether the claimant's medical impairments have improved to the point where [s]he is able to perform substantial gainful activity."). "This 'medical improvement' standard requires the Commissioner to compare a claimant's current condition with the condition existing at the time the claimant was found disabled and awarded benefits."
(8) if the claimant is unable to do work performed in the past, whether the claimant can perform other work.Delph v. Astrue, 538 F.3d 940, 945-46 (8th Cir. 2008). This eight-step analysis includes the five steps followed in an initial disability determination. Delph, 538 F.3d at 946.
When benefits have been denied based on a determination that a claimant's disability has ceased, the issue is whether the claimant's medical impairments have improved to the point where she is able to perform substantial gainful activity. Delph v. Astrue, 538 F.3d 940, 945-46 (8th Cir. 2008); see 42 U.S.C. § 423(f)(1). This "medical improvement" standard requires the Commissioner to compare a claimant's current condition with the condition existing at the time the claimant was found disabled and awarded benefits.