## Facts

- Carol A. Marciniak, a 43-year-old high school graduate, worked about ten years as a school library aide.
- She was laid off on May 31, 1990 due to staff reductions and alleged disability beginning that date based on back and neck problems.
- Her medical history included scoliosis treated in adolescence, later adult idiopathic scoliosis, and a June 1988 spinal fusion with Harrington rod instrumentation.
- She returned to work after surgery; in April 1990 she fell at work, twisting her neck and back, but returned two days later and worked until the layoff.
- In October 1990, imaging showed a small disc herniation; she was advised to continue general exercise and could return to work with restrictions on certain neck movements and prolonged fixed-neck positioning.
- In April 1991, a workers’ compensation evaluation documented headaches, shoulder and back pain, spinal pain, finger numbness, and diagnoses including thoracolumbar scoliosis with multi-level arthritis and degenerative disc disease.
- Treatment and activity evidence included primarily aspirin use, occasional hydrocodone for severe pain, and walking about two miles daily for exercise.
- An ALJ denied disability insurance benefits; the district court affirmed on summary judgment; Marciniak appealed.

## Issues

1. Whether substantial evidence supported the ALJ’s finding that Marciniak retained the residual functional capacity to perform a range of light work and other jobs in the national economy.
2. Whether the ALJ lawfully evaluated and partially discredited Marciniak’s subjective complaints of pain and functional limitation.

## Decision

- The Eighth Circuit affirmed the district court’s judgment upholding the denial of benefits.
- The court held substantial evidence on the record as a whole supported the Secretary’s determination that Marciniak was not disabled during the relevant period.
- The court accepted the ALJ’s light-work RFC finding as supported by medical evidence and reported activities.
- The court upheld the ALJ’s credibility determination discounting the full extent of Marciniak’s pain allegations.
- The court concluded that vocational expert testimony, based on the ALJ’s RFC, supported the step-five finding that jobs existed in significant numbers that she could perform.

## Legal Principles

- Judicial review of Social Security disability decisions asks whether the agency decision is supported by substantial evidence on the record as a whole; the reviewing court does not reweigh evidence or substitute its judgment.
- An ALJ may discount subjective pain complaints when inconsistencies exist between alleged limitations and evidence such as daily activities, medication use, medical recommendations, and objective findings, so long as the ALJ applies the relevant credibility factors and explains the determination.
- At step five, the Secretary may meet the burden to show other work exists by relying on vocational expert testimony responsive to a properly supported RFC; vocational testimony premised on fully credited subjective complaints does not control if the ALJ reasonably discredits those complaints.

## Conclusion

The Eighth Circuit affirmed the denial of disability insurance benefits because substantial evidence supported the ALJ’s light-work residual functional capacity finding, the partial discrediting of Marciniak’s subjective pain complaints, and the step-five determination—based on vocational expert testimony—that she could perform other work available in significant numbers.


Marciniak v. Shalala, 49 F.3d 1350 (8th Cir. 1995)