Ausburn v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedOctober 31, 2022
Docket4:21-cv-01145
StatusUnknown

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

Bluebook
Ausburn v. Social Security Administration, (E.D. Ark. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

ARTHUR HAROLD AUSBURN PLAINTIFF

V. No. 4:21-CV-1145-BRW-JTR

KILOLO KIJAKAZI, Acting Commissioner, Social Security Administration DEFENDANT

RECOMMENDED DISPOSITION

This Recommended Disposition (“Recommendation”) has been sent to United States District Judge Billy Roy Wilson. Either party may file written objections to this Recommendation. If objections are filed, they should be specific and should include the factual or legal basis for the objection. To be considered, objections must be received in the office of the Court Clerk within 14 days of this Recommendation. If no objections are filed, Judge Wilson can adopt this Recommendation without independently reviewing the record. By not objecting, parties may also waive the right to appeal questions of fact. I. Introduction On January 30, 2020, Arthur Harold Ausburn (“Ausburn”) filed a Title II application for a period of disability and disability insurance benefits. (Tr. at 11). In the application, she alleged disability beginning on June 1, 2019. Id. In a written decision dated June 3, 2021, an administrative law judge (“ALJ”) denied the application. (Tr. at 11–23). The Appeals Council denied Ausburn’s request for review on June 3, 2021. (Tr. at 1-4). The ALJ’s decision now stands as the final

decision of the Commissioner, and Ausburn has requested judicial review. For the reasons stated below, the Court concludes that the Commissioner’s decision should be affirmed.

II. The ALJ=s Decision At Step One of the required five-step analysis, the ALJ found that Ausburn had not engaged in substantial gainful activity since June 1, 2019.1 (Tr. at 13). At Step Two, the ALJ determined that Ausburn has the following severe impairments:

(1) degenerative disc disease and scoliosis of the lumbar spine; (2) retinal edema and vitelliform foveomacular dystrophy of the right eye;2 (3) post-traumatic stress disorder; (4) anti-social personality disorder; and (5) polysubstance abuse disorder. Id.

At step three, the ALJ determined that Ausburn’s impairments did not meet or equal a listed impairment (Tr. at 14–16).3

1 20 C.F.R. §§ 404.1520(a)–(g), 416.920(a)–(g).

2 Adult-onset foveomacular vitelliform dystrophy goes by a few different names, but its “egg yolk” presentation remains a consistent finding in affected eyes. Depending on the disease stage, most patients have few symptoms and only mild visual impairment. https://www.reviewofophthalmology.com/article/sunny-side-up-vitelliform-dystrophy

3 20 C.F.R. Part 404, Subpt. P, Appendix 1 (20 C.F.R. §§ 404.1520(d), 404.1525, and 404.1526). The ALJ determined that Ausburn had the residual functional capacity (“RFC”) to perform work at the light exertional level, with additional limitations;

(1) he could no more than occasionally climb, stoop, kneel, crouch, and crawl; (2) he is limited to reading ordinary newspaper or book print, but no fine print; (3) he is limited to simple routine, repetitive work, making simple work-related decisions;

and (4) he can have occasional interaction with supervisors, co-workers, and the public. (Tr. at 16–17). At Step Four, the ALJ found that Ausburn was unable to perform any of his past relevant work. (Tr. at 21). At Step Five, the ALJ relied upon Vocational Expert

(“VE”) testimony to find that, based on Ausburn’s age, education, work experience and RFC, jobs existed in significant numbers in the national economy that he could perform, including positions such as router, assembler, and bakery worker. (Tr. at

22). Thus, the ALJ concluded that Ausburn was not disabled. Id. III. Discussion A. Standard of Review The Court’s function on review is to determine whether the Commissioner’s

decision is supported by substantial evidence on the record as a whole and whether it is based on legal error. Miller v. Colvin, 784 F.3d 472, 477 (8th Cir. 2015); see also 42 U.S.C. § 405(g). While “substantial evidence” is that which a reasonable mind might accept as adequate to support a conclusion, “substantial evidence on the record as a whole” requires a court to engage in a more scrutinizing analysis:

Our review is more than an examination of the record for the existence of substantial evidence in support of the Commissioner’s decision; we also take into account whatever in the record fairly detracts from that decision. Reversal is not warranted, however, merely because substantial evidence would have supported an opposite decision.

Reed v. Barnhart, 399 F.3d 917, 920 (8th Cir. 2005) (citations omitted). In clarifying the “substantial evidence” standard applicable to review of administrative decisions, the Supreme Court has explained: “And whatever the meaning of ‘substantial’ in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence . . . ‘is more than a mere scintilla.’” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (quoting Consolidated Edison Co. v. NLRB, 59 S. Ct. 206, 217 (1938)). “It means—and means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Id. B. Ausburn’s Arguments on Appeal Ausburn contends that the evidence supporting the ALJ’s decision to deny benefits is less than substantial. He argues that the ALJ erred at Step Five by failing

to recognize and resolve a conflict between the VE’s testimony and the Dictionary of Occupational Titles (“DOT”). Ausburn’s claim relates to his right eye condition, and the Court limits its discussion to that impairment.4

Ausburn was diagnosed with retinal edema and vitelliform foveomacular dystrophy of the right eye. (Tr. at 302, 397–398). Ausburn received intravitreal injections and used Refresh eye drops. (Tr. at 289–306). The record reflects that his

left eye vision is 20/20, while his right eye vision is 20/40. (Tr. at 456). Ausburn wears prescription glasses (Tr. at 39). After his final intravitreal injection in February 2021, he was told simply to follow-up in six weeks. (Tr. at 500–504). Ausburn said that he could not read out of his right eye, but he admitted to

using his phone when he checked his Facebook account. (Tr. at 42–43). No doctor placed visual functional restrictions on Ausburn. He did not require aggressive treatment.

The Disability Determination Services (“DDS”) medical experts reviewed the records and found that Ausburn had no visual limitations. (Tr. at 66, 80). The ALJ considered the DDS opinions and decided that Ausburn did have some visual limitation. In the RFC, the ALJ limited Ausburn to reading ordinary newspaper or

4 See Noerper v. Saul, 964 F.3d 738, 741 (8th Cir. 2020) (“Although our detailed discussion is targeted, we have considered the claimant’s arguments and the record as a whole as to all of her impairments and their cumulative effect on her limitations.”) book print, but not fine print. (Tr. at 55). Ausburn argues that the ALJ ‘s limitation would have ruled out the jobs which the VE identified.5

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Ausburn v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ausburn-v-social-security-administration-ared-2022.