Ault v. SSA

2012 DNH 005
CourtDistrict Court, D. New Hampshire
DecidedJanuary 10, 2012
DocketCV-10-553-JL
StatusPublished
Cited by2 cases

This text of 2012 DNH 005 (Ault v. SSA) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ault v. SSA, 2012 DNH 005 (D.N.H. 2012).

Opinion

Ault v. SSA CV-10-553-JL 1/10/12

UNITED STATES DISTRICT COURT DISTRICT OF NEW HAMPSHIRE

Stephanie V . Ault v. Civil N o . 10-cv-553-JL Opinion N o . 2012 DNH 005 Michael J. Astrue, Commissioner, Social Security Administration

MEMORANDUM ORDER

This is an appeal from the denial of a claimant’s

application for Social Security Disability Benefits. See 42

U.S.C. § 405(g). The claimant, Stephanie Ault, contends that the

administrative law judge (“ALJ”) incorrectly found that although

Ault was severely impaired by degenerative joint disease in her

left knee and left femoral neuropathy, Admin. R. 14; 1 see 20

C.F.R. §§ 404.1520 (a),(c), she retained the residual functional

capacity2 (“RFC”) to perform light work, Admin. R. 1 5 ; see 20

C.F.R. § 404.1567(b), and that she remained capable of performing

her past work as a receptionist at a laboratory, nail technician,

1 The court will reference the administrative record (“Admin. R.”) to the extent that it recites facts contained in or directly quotes documents from the record. C f . Lalime v . Astrue, N o . 08- cv-196-PB, 2009 WL 995575, at *1 (D.N.H. Apr. 1 4 , 2009). 2 “Residual Functional Capacity” is defined as “an assessment of an individual’s ability to do sustained work-related physical and mental activities in a work setting on a regular and continuing basis. A ‘regular and continuing basis’ means 8 hours a day, for 5 days a week, or an equivalent work schedule.” SSR 96-8p, 1996 WL 374184, at *1 (July 2 , 1996). and customer service representative. Admin. R. 1 7 ; see 20 C.F.R.

§ 404.1520(a)(4)(iv). Ault contends that the ALJ committed

reversible error at steps two through five of the five step

disability analysis.3 Specifically, Ault alleges that the ALJ:

(1) failed to properly analyze Ault’s impairments at Step 2 and erroneously concluded that her pancreatitis, migraine headaches, myofascial pain, and depression were not severe,4 Admin. R. 1 4 ; C l . B r . 8-13,

3 The social security regulations set forth a five step procedure to determine if a claimant is disabled. 20 C.F.R. § 404.1520(a)(4). The claimant bears the burden in the first four steps to show that: (1) she is not engaged in substantial gainful activity; (2) she has a severe impairment; (3) the impairment meets or equals a specific impairment listed in the Social Security regulations; or (4) the impairment prevents or prevented her from performing past relevant work. At Step 5 of the analysis, it is the Commissioner’s burden to establish that jobs exist in the national economy given the claimant’s impairments, age, education, and work experience. See id. 4 Ault also contends that the ALJ erred in failing to mention the effects of hypothyroidism, asthma, and the side-effects of her medications. Admin. R. 14-15. The court finds no error as none of these impairments were mentioned in Ault’s “Disability Report,” and were only briefly mentioned during the hearing. Id. at 31-33, 35-36, 124. Indeed, asthma was only mentioned in response to a question about a list of medications, but not discussed as an impairment. Id. at 3 5 . Hypothyroidism and side- effects from medication were mentioned almost as an afterthought in response to prompting by her attorney and even then, Ault stated that due to hypothyroidism “and some of the other medications I’m o n , I could be tired. I find myself dozing off sometimes, and sometimes it can be while I am driving, and sometimes it’s at work.” Id. at 3 6 . Although a claimant’s burden at Step 2 is de minimis, see LaBonte v . Astrue, N o . 09- 358-P-S, 2010 WL 2024895, at *2 (D. M e . May 1 8 , 2010), mere mention of an impairment without further development does not satisfy this burden. See id. Ault hardly demonstrates that these impairments significantly limit her “ability to do basic work activities.” 20 C.F.R. § 404.1520(c). The court finds no

2 (2) failed to determine that her left knee injury and left femoral neuropathy qualified as a listed impairment in 20 C.F.R. Part 4 0 4 , Subpart P, Append ix 1 , see Admin. R. 1 5 ; C l . B r . 13-14; see generally 20 C.F.R. §§ 404.1520(a)(4)(iii),(d), 404.1525, 404.1526,

(3) improperly assigned greater weight to the opinion of a non-examining physician, and did not grant controlling weight to a treating physician’s functional assessment, C l . B r . 17-19, see generally 20 C.F.R. §§ 404.1502, 404.1527(d); SSR 96-2p, 1996 WL 374188 (July 2 , 1996), and

(4) failed at Step 4 to take into account Ault’s allegations of disabling depression, migraine headaches, pancreatitis, hypothyroidism, neck pain, and asthma when determining her RFC.5 See C l . B r . 14-17.

The Commissioner asserts that the ALJ’s findings are supported by

substantial evidence in the record, and moves for an order

affirming his decision. This court has subject-matter

jurisdiction under 28 U.S.C. § 1331 (federal question) and 42

U.S.C. § 405(g) (Social Security). After a review of the

administrative record, the court concludes that although the ALJ

properly determined Ault’s severe impairments at Step 2 , he did

not account for these impairments when fashioning Ault’s RFC at

Step 4 . The court also finds error in the ALJ’s treatment of an

error. C f . Lacroix v . Barnhart, 352 F. Supp. 2d 1 0 0 , 115 (D. Mass. 2005). 5 Ault also inexplicably contends there was error at Step 5 . C l . B r . 17-19. The ALJ determined that Ault was not disabled at Step 4 , Admin. R. 1 7 , and therefore did not reach Step 5 . The court will not address this claim of error.

3 opinion rendered by Ault’s treating physician. The court grants

Ault’s motion, denies the Commissioner’s motion, and remands for

further proceedings.

I. APPLICABLE LEGAL STANDARD

The court’s review under Section 405(g) is “limited to

determining whether the ALJ deployed the proper legal standards

and found facts upon the proper quantum of evidence.” Nguyen v .

Chater, 172 F.3d 3 1 , 35 (1st Cir. 1999); see Simmons v . Astrue,

736 F. Supp. 2d 3 9 1 , 399 (D.N.H. 2010). If the ALJ’s factual

findings are supported by substantial evidence in the record,

they are conclusive, even if the Court does not agree with the

ALJ’s decision and other evidence supports a contrary conclusion.

See Tsarelka v . Sec’y of Health & Human Servs., 842 F.2d 529, 535

(1st Cir. 1988). Substantial evidence is “such relevant evidence

as a reasonable mind might accept as adequate to support a

conclusion.” Richardson v . Perales, 402 U.S. 389, 401 (1971)

(quotations omitted). The ALJ is responsible for determining

issues of credibility, resolving conflicting evidence, and

drawing inferences from the evidence in the record. See

Rodriguez v . Sec’y of Health & Human Servs., 647 F.2d 2 1 8 , 222

(1st Cir. 1981); Pires v .

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