Anderson v. Saul

CourtDistrict Court, E.D. Missouri
DecidedDecember 29, 2021
Docket4:20-cv-00908
StatusUnknown

This text of Anderson v. Saul (Anderson v. Saul) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. Saul, (E.D. Mo. 2021).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

JOHN ANDERSON, JR., ) ) Plaintiff, ) ) vs. ) Case No. 4:20 CV 908 ACL ) KILOLO KIJAKAZI, ) Acting Commissioner of Social Security ) Administration,1 ) ) Defendant. )

MEMORANDUM

Plaintiff John Anderson, Jr., brings this action pursuant to 42 U.S.C. § 405(g), seeking judicial review of the Social Security Administration Commissioner’s denial of his applications for Disability Insurance Benefits (“DIB”) under Title II of the Social Security Act and Supplemental Security Income (“SSI”) under Title XVI of the Act. An Administrative Law Judge (“ALJ”) found that, despite Anderson’s severe impairments, he was not disabled as he had the residual functional capacity (“RFC”) to perform work existing in significant numbers in the national economy. This matter is pending before the undersigned United States Magistrate Judge, with consent of the parties, pursuant to 28 U.S.C. § 636(c). A summary of the entire record is presented in the parties’ briefs and is repeated here only to the extent necessary.

1Kilolo Kijakazi became the Acting Commissioner of Social Security on July 9, 2021. Pursuant to Federal Rule of Appellate Procedure 43(c)(2), Kilolo Kijakazi is substituted for Andrew Saul as defendant in this action. No further action is needed for this action to continue. See 42 U.S.C. § 405(g) (last sentence).

Page 1 of 23 For the following reasons, the decision of the Commissioner will be affirmed. I. Procedural History On November 6, 2017, Anderson filed his applications for DIB and SSI benefits. (Tr. 163, 165.) He claimed that he became unable to work on January 1, 2013, due to degenerative

disc disease, diabetes, depression, nerve pain, pain, and hypertension. (Tr. 188.) Anderson was 37 years of age at his alleged onset of disability date. His applications were denied initially. (Tr. 85.) Anderson’s claims were denied by an ALJ on June 17, 2019. (Tr. 11-21.) In her opinion, the ALJ noted that Anderson had filed a prior application for benefits. (Tr. 11, 52.) The ALJ stated that she was not reopening the prior decision, and explained that the decision at issue would only consider Anderson’s eligibility for benefits since August 19, 2015—the date following the date his prior denial became final. Id. On May 28, 2020, the Appeals Council denied Anderson’s claim for review. (Tr. 1-5.) Thus, the decision of the ALJ stands as the final decision of the Commissioner. See 20 C.F.R. §§ 404.981, 416.1481. In this action, Anderson argues that the ALJ “failed to properly evaluate RFC.” (Doc.

24 at 3.) II. The ALJ’s Determination The ALJ first found that Anderson met the insured status requirements of the Social Security Act through December 31, 2017. (Tr. 442.) She stated that Anderson has not engaged in substantial gainful activity since August 19, 2015, the start of the period at issue. Id. In

addition, the ALJ concluded that Anderson had the following severe impairments: diabetes mellitus and degenerative disc disease. (Tr. 14.) The ALJ found that Anderson did not have an impairment or combination of impairments that met or medically equaled the severity of one of Page 2 of 23 the listed impairments. (Tr. 15.) As to Anderson’s RFC, the ALJ stated: After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform sedentary work as defined in 20 CFR 404.1567(a) and 416.967(a), except: He should never climb ropes, ladders, or scaffolds, but can occasionally climb ramps and stairs, balance, stoop, kneel, crouch, and crawl. He should have no concentrated exposure to vibration, unprotected heights, or hazardous machinery.

Id. The ALJ found that Anderson was unable to perform past relevant work, but could perform other jobs existing in significant numbers in the national economy, such as addresser, document preparer, and information clerk. (Tr. 19-20.) The ALJ therefore concluded that Anderson was not under a disability, as defined in the Social Security Act, from August 19, 2015, through the date of the decision. (Tr. 20.) The ALJ’s final decision reads as follows: Based on the application for a period of disability and disability insurance benefits protectively filed on November 6, 2017, the claimant is not disabled under sections 216(i) and 223(d) of the Social Security Act.

Based on the application for supplemental security income protectively filed on November 6, 2017, the claimant is not disabled under section 1614(a)(3)(A) of the Social Security Act.

(Tr. 21.)

III. Applicable Law III.A. Standard of Review The decision of the Commissioner must be affirmed if it is supported by substantial Page 3 of 23 evidence on the record as a whole. 42 U.S.C. § 405(g); Richardson v. Perales, 402 U.S. 389, 401 (1971); Estes v. Barnhart, 275 F.3d 722, 724 (8th Cir. 2002). Substantial evidence is less than a preponderance of the evidence, but enough that a reasonable person would find it adequate to support the conclusion. Johnson v. Apfel, 240 F.3d 1145, 1147 (8th Cir. 2001). This

“substantial evidence test,” however, is “more than a mere search of the record for evidence supporting the Commissioner’s findings.” Coleman v. Astrue, 498 F.3d 767, 770 (8th Cir. 2007) (internal quotation marks and citation omitted). “Substantial evidence on the record as a whole . . . requires a more scrutinizing analysis.” Id. (internal quotation marks and citations omitted). To determine whether the Commissioner’s decision is supported by substantial evidence on the record as a whole, the Court must review the entire administrative record and consider: 1. The credibility findings made by the ALJ.

2. The plaintiff’s vocational factors.

3. The medical evidence from treating and consulting physicians.

4. The plaintiff’s subjective complaints relating to exertional and non-exertional activities and impairments.

5. Any corroboration by third parties of the plaintiff’s impairments.

6. The testimony of vocational experts when required which is based upon a proper hypothetical question which sets forth the claimant’s impairment.

Stewart v. Secretary of Health & Human Servs., 957 F.2d 581, 585-86 (8th Cir. 1992) (internal citations omitted). The Court must also consider any evidence which fairly detracts from the Page 4 of 23 Commissioner’s decision. Coleman, 498 F.3d at 770; Warburton v. Apfel, 188 F.3d 1047, 1050 (8th Cir. 1999).

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Related

Halverson v. Astrue
600 F.3d 922 (Eighth Circuit, 2010)
Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Martise v. Astrue
641 F.3d 909 (Eighth Circuit, 2011)

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Anderson v. Saul, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-saul-moed-2021.