## Facts

- Lorraine Polaski challenged the termination of her Social Security disability benefits and amended her complaint to seek class relief for similarly situated claimants within the Eighth Circuit.
- The class alleged the Secretary of Health and Human Services applied unlawful standards by (1) terminating benefits without evidence of material medical improvement or error in the original award and (2) requiring objective medical evidence to fully corroborate subjective pain and other symptoms.
- The district court certified a class and issued a preliminary injunction requiring the Secretary to follow Eighth Circuit standards for benefit terminations and for evaluating subjective complaints, and it ordered reconsideration of class members’ claims under those standards.
- The Secretary appealed the preliminary injunction.
- While the appeal was pending, the parties submitted a stipulation stating the controlling standard for evaluating subjective pain and other symptoms in disability adjudications.

## Issues

1. Whether the district court properly granted circuit-wide preliminary injunctive and class relief based on the Secretary’s alleged failure to apply Eighth Circuit standards for benefit terminations and subjective-symptom evaluation.
2. What standard governs assessment of a claimant’s subjective complaints of pain and other symptoms when objective medical evidence does not fully substantiate the complaints.
3. Whether the preliminary injunction and related class relief should be modified or reconsidered in light of the parties’ stipulation and controlling circuit precedent.

## Decision

- The court accepted and adopted the parties’ stipulation as a correct statement of governing law in the Eighth Circuit for evaluating pain and other subjective symptoms in disability cases.
- The court remanded for further proceedings so the district court could reconsider the scope and terms of injunctive and class relief in light of the adopted standard and applicable circuit law, including standards governing termination of previously awarded benefits.

## Legal Principles

- A claimant must establish a medically determinable impairment, but adjudicators may not require objective medical evidence to directly prove the degree of alleged pain or other subjective symptoms.
- Subjective complaints may not be rejected solely because objective medical evidence does not fully support them; lack of objective support is only one factor in the analysis.
- Credibility assessment must consider the whole record, including the claimant’s complaints, prior work record, third-party observations, and treating/examining physician observations.
- In evaluating subjective symptoms, adjudicators must consider: (1) daily activities; (2) duration, frequency, and intensity of pain; (3) precipitating and aggravating factors; (4) dosage, effectiveness, and side effects of medication; and (5) functional restrictions.
- An ALJ may not accept or reject subjective complaints solely based on the ALJ’s personal observations, but may discount complaints that conflict with the total administrative record if reasons are grounded in that record.
- For terminations of benefits, agency decisionmaking must follow circuit precedent requiring evidence supporting termination (including consideration of material improvement or error in the prior award), subject to further district court consideration on remand regarding appropriate class-wide relief.

## Conclusion

The Eighth Circuit formalized a mandatory, multi-factor framework for evaluating subjective pain and similar symptoms in disability cases and remanded to allow reconsideration of class-wide injunctive relief, including relief addressing standards for terminating previously granted benefits, consistent with circuit law.


Polaski v. Heckler, 751 F.2d 943 (8th Cir. 1984)