Summary
affirming ALJ's decision to deny benefits, and dispatching with the same argument that Young makes in the instant case
Summary of this case from Young v. KijakaziOpinion
22-2619
03-07-2023
Rita Jarmon Plaintiff - Appellant v. Kilolo Kijakazi, Acting Commissioner of Social Security Administration Defendant-Appellee
Unpublished
Submitted: March 1, 2023
Appeal from United States District Court for the Eastern District of Arkansas - Central
Before LOKEN, KELLY, and KOBES, Circuit Judges.
PER CURIAM.
Rita Jarmon appeals the district court's order affirming the denial of disability insurance benefits. Jarmon argues that the administrative law judge (ALJ) erred in evaluating the opinion of her one-time treating physician under 20 C.F.R. § 404.1520c. We find that the ALJ properly evaluated the opinion, as that regulation applies to claims--like Jarmon's--filed after March 27, 2017, and explicitly abrogates the treating source rule; and as the ALJ considered the supportability and consistency of the opinion. See Austin v. Kijakazi, 52 F.4th 723, 728-30 (8th Cir. 2022) (under revised regulations, treating physicians' opinions are no longer entitled to special deference; finding that prior precedent applying treating-source rule was inapposite, and that ALJ adequately analyzed opinion by addressing its supportability and consistency). Thus, we find that substantial evidence in the record as a whole supports the ALJ's adverse decision. See Kraus v. Saul, 988 F.3d 1019, 1023-24 (8th Cir. 2021) (standard of review).
The Honorable Brian S. Miller, United States District Judge for the Eastern District of Arkansas, adopting the report and recommendations of the Honorable Joe J. Volpe, United States Magistrate Judge for the Eastern District of Arkansas.
The judgment is affirmed.