Austin v. Social Security Administration

District Court, E.D. Arkansas·Decided February 10, 2022·No. 3:20-cv-00351·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS NORTHERN DIVISION

LISA AUSTIN PLAINTIFF

V. NO. 3:20-CV-00351-JTK

KILOLO KIJAKAZI, COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION1 DEFENDANT

ORDER

I. Introduction:

Plaintiff, Lisa Austin (“Austin”), applied for disability benefits on March 27, 2018, alleging a disability onset date of February 28, 2018. (Tr. at 13). The claim was denied initially and upon reconsideration. Id. After conducting a hearing, the Administrative Law Judge (“ALJ”) denied Austin’s application on February 5, 2020. (Tr. at 26). The Appeals Council denied her request for review. (Tr. at 1). The ALJ=s decision now stands as the final decision of the Commissioner, and Austin has requested judicial review. For the reasons stated below, the Court2 affirms the decision of the Commissioner. II. The Commissioner=s Decision: The ALJ found that Austin had not engaged in substantial gainful activity since the alleged onset date of February 28, 2018.3 (Tr. at 16). The ALJ found, at Step Two, that Austin had the

1 On July 9, 2021, Kilolo Kijakazi became the Acting Commissioner of the Social Security Administration and is substituted as the Defendant in this action. Fed. R. Civ. P. 25(d).

2 The parties have consented in writing to the jurisdiction of a United States Magistrate Judge.

3 The ALJ followed the required five-step sequence to determine: (1) whether the claimant was engaged in substantial gainful activity; (2) if not, whether the claimant had a severe impairment; (3) if so, whether the impairment (or combination of impairments) met or equaled a listed impairment; (4) if not, whether the impairment (or combination of impairments) prevented the claimant from performing past relevant work; and (5) if so, whether the impairment (or combination of impairments) prevented the claimant from following severe impairments: migraines, anxiety disorder, mood disorder. Id. After finding that Austin’s impairments did not meet or equal a listed impairment (Tr. at 16), the ALJ determined that Austin had the residual functional capacity (“RFC”) to perform work at the light exertional level with exceptions: (1) she should avoid extreme cold and wetness, work

in direct sunlight, and loud noises; (2) she can perform simple, routine, repetitive tasks as well as make simple, work-related decisions; (3) she can concentrate, persist, and maintain pace with normal breaks; and (4) she can tolerate interpersonal contact with supervision that is simple, direct, and concrete. (Tr. at 18). The ALJ found that Austin was unable to perform any of her past relevant work. (Tr. at 23). At Step Five, the ALJ relied upon Vocational Expert (“VE”) testimony to find that, based on Girard’s age, education, work experience and RFC, jobs existed in significant numbers in the national economy that she could perform. (Tr. at 25). Therefore, the ALJ found that Austin 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

performing any other jobs available in significant numbers in the national economy. 20 C.F.R. §§ 404.1520(a)-(g), 416.920(a)-(g).

2 analysis: “[O]ur 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. Austin=s Arguments on Appeal Austin contends that the evidence supporting the ALJ’s decision is less than substantial. She argues that: (1) the ALJ did not properly evaluate medical opinions; (2) the RFC did not incorporate all of her limitations; and (3) the ALJ failed to consider Austin’s work experience. For the following reasons, the Court finds that substantial evidence supports the ALJ=s decision. Austin’s attorney admitted that Austin’s main impairment was her migraine headaches. (Tr. at 35). She suffered some anxiety and depression but did not receive regular psychiatric treatment for that. Austin’s migraines improved with the implantation of a spinal cord stimulator in 2018, and she said that she was very pleased with the treatment. (Tr. at 41-49, 384-386). Improvement in condition supports an ALJ’s finding that a claimant is not disabled. See Lochner v. Sullivan, 968,

3 F.2d 725, 728 (8th Cir. 1992). Austin said at the hearing that she was “still good” and that she had not been to the hospital more than once for headaches since the treatment began. (Tr. at 40-42). She also said chiropractic treatment helped, and she said she could do things like light chores, cooking, driving, watching TV, and driving. (Tr. at 45-47). Such daily activities undermine her

claims of disability. Edwards v. Barnhart, 314 F.3d 964, 967 (8th Cir. 2003). Furthermore, one doctor recommended that she exercise and lose weight for symptom control. (Tr. at 397). See Moore v. Astrue, 572 F.3d 520, 524 (8th Cir. 2009) (encouragement to exercise constituted evidence in support of ALJ’s findings); On October 29, 2018, Austin underwent a neurophysiological evaluation with Kristin Addison-Brown, Ph.D. (Tr. at 397-400). Austin presented with appropriate affect and linear thought-process with normal sensory and motor skills. Id. Dr. Brown recommended conservative treatment. But Dr. Brown said that Austin had working memory deficits and poor organization. Id. The ALJ found Dr. Brown’s opinion to be non-persuasive and gave good reasons for doing so.4 (Tr. at 21). She pointed to generally normal mental status exams and the fact that Austin did not

seek out mental health treatment. Id. This analysis was proper. Dr. Dennis Vowell, Psy.D examined Austin on January 13, 2019, and noted a relatively

4 On January 28, 2017, the Administration promulgated new regulations governing how ALJs assess medical opinion evidence.

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