Rita Jarmon v. Kilolo Kijakazi, Acting Commissioner of Social Security Administration

United States Court of Appeals
For the Eighth Circuit
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No. 22-2619
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Rita Jarmon
lllllllllllllllllllllPlaintiff - Appellant
v.
Kilolo Kijakazi, Acting Commissioner of Social Security Administration
lllllllllllllllllllllDefendant - Appellee
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Appeal from United States District Court
for the Eastern District of Arkansas - Central
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Submitted: March 1, 2023
Filed: March 7, 2023
[Unpublished]
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Before LOKEN, KELLY, and KOBES, Circuit Judges.
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PER CURIAM.

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Rita Jarmon appeals the district court’s1 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 judgment is affirmed.
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1The 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.
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