## Facts

- Shirley Shontos applied for Disabled Widow’s Benefits in December 1998 after her husband’s death, alleging disability from multiple physical and mental impairments, including borderline intellectual functioning and depressive and anxiety disorders.
- At the relevant time, she was 50 years old, had a ninth-grade education, and essentially no outside work history.
- A consultative psychologist administered IQ testing and reported significant difficulties with intellectual functioning and below-average verbal and non-verbal abilities.
- Shontos received longitudinal mental-health treatment at the Gannon Center from an interdisciplinary team that included a psychologist, a certified counselor, and a nurse practitioner.
- The treating team repeatedly diagnosed major depression and anxiety disorders and assessed severe work-related functional limitations.
- Non-examining state-agency psychologists reviewed records and concluded her mental impairments did not meet or equal a listing and that she could perform simple tasks.
- An ALJ denied benefits, finding no listing-level impairment or equivalence and concluding Shontos retained residual functional capacity for certain work, giving greater weight to the state-agency reviewers and discounting the treating team because some providers were not “acceptable medical sources.”
- The Appeals Council denied review, and the district court affirmed the Commissioner’s decision.

## Issues

1. Whether substantial evidence supported the denial of Disabled Widow’s Benefits where the ALJ discounted consistent, longitudinal opinions from an interdisciplinary mental-health treatment team.
2. Whether the ALJ erred in relying primarily on non-examining state-agency reviewers to reject listing-level severity or equivalence for Shontos’s mental impairments.
3. Whether the proper remedy, on this record, was remand for further proceedings or remand with instructions to award benefits.

## Decision

- The Eighth Circuit reversed the district court’s judgment.
- The court held the ALJ’s denial was not supported by substantial evidence because the ALJ improperly evaluated and discounted the treating mental-health team’s integrated and consistent assessments.
- The court concluded the record, properly weighed, supported listing-level severity or equivalence for Shontos’s mental impairments.
- The case was remanded with instructions that benefits be awarded, because the record was fully developed and further proceedings would only delay payment.

## Legal Principles

- An ALJ must meaningfully evaluate longitudinal, coordinated treating-source evidence in mental-impairment cases; opinions from counselors and nurse practitioners may not be disregarded when they are part of an integrated treatment process supervised and supported by an acceptable medical source (such as a psychologist).
- Non-examining state-agency reviewers’ opinions, standing alone, generally do not constitute substantial evidence when they conflict with consistent treating-team observations and functional assessments based on direct clinical contact over time.
- In evaluating whether impairments meet or equal a listed impairment, the agency must consider the combined effect of intellectual limitations and psychiatric conditions and the resulting functional limitations shown by the record.
- Internal administrative guidance may inform the analysis; while it does not bind the agency as law, it should be considered where relevant to evaluating mental-impairment evidence.
- A court may order an immediate award of benefits when the record compels a disability finding and additional administrative proceedings would serve only to delay benefits.

## Conclusion

The Eighth Circuit held that the denial of Disabled Widow’s Benefits lacked substantial evidence because the ALJ improperly discounted an integrated treating mental-health team’s consistent, longitudinal assessments in favor of non-examining reviewers, and it remanded with instructions to award benefits given the fully developed record.


Shontos v. Barnhart, 328 F.3d 418 (8th Cir. 2003)