Austin v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedApril 17, 2023
Docket3:22-cv-00100
StatusUnknown

This text of Austin v. Social Security Administration (Austin 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
Austin v. Social Security Administration, (E.D. Ark. 2023).

Opinion

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

JENNY AUSTIN PLAINTIFF

V. NO. 3:22-CV-00100-JTK

COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION DEFENDANT

ORDER

I. Introduction:

Plaintiff, Jenny Austin (“Austin”), applied for disability benefits on January 5, 2018, alleging a disability onset date of July 15, 2015.1 (Tr. at 15). The claim was denied initially and upon reconsideration. Id. After conducting a hearing, the Administrative Law Judge (“ALJ”) denied Austin’s application on July 28, 2021. (Tr. at 29). The Appeals Council denied her request for review. (Tr. at 1-4). 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 Court 2 affirms the decision of the Commissioner. II. The Commissioner=s Decision: The ALJ found that Austin had not engaged in substantial gainful activity

1 Austin later amended her onset date to January 1, 2019. Id. 2 The parties have consented in writing to the jurisdiction of a United States Magistrate Judge. since the alleged onset date of January 1, 2019.3 (Tr. at 18). The ALJ found, at Step Two, that Austin had the following severe impairments: migraine headaches, seizure

disorder, bilateral carpal tunnel syndrome, cervical degenerative changes, left shoulder degenerative changes, diabetes mellitus, tachycardia, autonomic neuropathy, obesity, anxiety, and depression. Id.

After finding that Austin’s impairments did not meet or equal a listed impairment (Tr. at 19-21), the ALJ determined that Austin had the residual functional capacity (“RFC”) to perform work at the light exertional level, with additional limitations: (1) she can no more than occasionally climb ramps or stairs,

but never climb ladders, ropes, or scaffolds; (2) she can no more than occasionally balance stoop, kneel, crouch, and crawl; (3) she cannot tolerate exposure to hazards, such as unprotected heights, vibration, and dangerous moving machinery; (4) she

cannot drive; (5) she can tolerate only occasional exposure to atmospheric conditions such as fumes, noxious odors, dust, mists, gases, and poor ventilation; (6) she can never work in loud or very loud noise environments; (7) she is limited to less than

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 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 constant use, but can frequently use the upper extremities to reach, handle, finger, and feel; (8) she can only occasionally overhead reach with the upper extremities;

and (9) she is limited to simple, routine, repetitive work, and simple work-related decisions. (Tr. at 21). At Step Four, the ALJ determined that Austin is unable to perform any of her

past relevant work (the ALJ noted that Austin had worked occasionally during the relevant time-period). (Tr. at 28). Relying upon testimony from a Vocational Expert (“VE”), the ALJ found, based on Austin’s age, education, work experience and RFC, that he could perform work in the national economy. (Tr. at 23-24). Representative

positions were Price Tag Ticketer, Cafeteria Assistant, and Sales Attendant. Id. Therefore, the ALJ concluded 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 analysis:

3 “[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 failed to resolve a conflict at Step Five; (2) the ALJ did not properly evaluate the opinion of Dr. Dennis Vowell, PsyD; (3) the ALJ failed to fully consider Austin’s conversion disorder; and (4) the ALJ did not

fully consider Austin’s alleged absenteeism due to medical treatment.

4 At Step Five, an ALJ must ensure that a VE’s testimony is sufficiently supported. Before relying on VE evidence to support a determination that a claimant

is not disabled, the ALJ has an affirmative responsibility to ask about "any possible conflict" between VE testimony and the Dictionary of Occupational Titles (“DOT”), and to obtain an explanation for any such conflict. Renfrow v. Colvin, 496 F.3d 918,

920-21 (8th Cir. 2007). Austin contends that because the jobs identified by the VE required frequent reaching and the RFC limited Austin to occasional reaching, she could not perform the representative jobs. (Doc. No. 17 at 5). More specifically, she argues that the ALJ failed to resolve this conflict.

The ALJ did ask the VE to resolve any underlying conflicts, and the VE specifically addressed reaching, stating: Your Honor, let me just first address that occasional overhead reach, which that limitation is not specifically addressed in the DOT. My answer is based on how the jobs described in the DOT [are] being performed and I use my knowledge, training, education, and experience to equate it within your hypotheticals.

(Tr. at 134-135). The ALJ then directly addressed this response in his opinion and found that the VE’s explanation was sufficient. (Tr. at 28-29). In multiple District Court cases where a VE recognizes a conflict, brings it up at the hearing and gives multiple reasons to explain how he considered it, the Court has found that the ALJ has met his burden at Step Five. See Porter v. Berryhill, 2018 U.S. Dist. LEXIS

5 37141 *42 (W.D. Mo. Mar. 7, 2018); Yeley v.

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Related

Renfrow v. Astrue
496 F.3d 918 (Eighth Circuit, 2007)
Charles Miller v. Carolyn W. Colvin
784 F.3d 472 (Eighth Circuit, 2015)
Reter v. Railroad Retirement Board
465 F.3d 896 (Eighth Circuit, 2006)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Veronica Grindley v. Kilolo Kijakazi
9 F.4th 622 (Eighth Circuit, 2021)

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Bluebook (online)
Austin v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/austin-v-social-security-administration-ared-2023.