Bastion v. Social Security Administration Commissioner

CourtDistrict Court, W.D. Arkansas
DecidedJanuary 13, 2023
Docket5:21-cv-05224
StatusUnknown

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

Bluebook
Bastion v. Social Security Administration Commissioner, (W.D. Ark. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS FAYETTEVILLE DIVISION

ASHLEY N. BASTION PLAINTIFF

v. CIVIL NO. 21-5224

KILOLO KIJAKAZI, Acting Commissioner DEFENDANT Social Security Administration

MAGISTRATE JUDGE’S REPORT AND RECOMMENDATIONS Plaintiff, Ashley N. Bastion, brings this action pursuant to 42 U.S.C. § 405(g), seeking judicial review of a decision of the Commissioner of the Social Security Administration (Commissioner) denying his claims for a period of disability and disability insurance benefits (“DIB”) under Title II of the Social Security Act (hereinafter “the Act”), 42 U.S.C. §§ 423(d)(1)(A). In this judicial review, the Court must determine whether there is substantial evidence in the administrative record to support the Commissioner’s decision. See U.S.C. § 405(g). I. Procedural Background: Plaintiff protectively filed her application for DIB on January 6, 2020, alleging an inability to work since November 1, 2019, due to scoliosis and a broken tailbone. (Tr. 24, 214). The ALJ issued an unfavorable decision on March 29, 2021. (Tr. 21–34). The ALJ found that Plaintiff had an impairment or combination of impairments that were severe: scoliosis of the spine status-post fusion with rods, hypertension, coronary artery disease, arthritis at C5-6, osteoarthritis, major depression, anxiety, and post-traumatic stress disorder. (Tr. 26). After reviewing all evidence presented, the ALJ determined that through the date last insured, Plaintiff’s impairments did not meet or equal the level of severity of any impairment in the Listing of Impairments found in 20 C.F.R., Subpart P, Appendix 1. (Tr. 26–30). The ALJ found Plaintiff retained the residual functional capacity (RFC) to perform light work but was additionally limited to jobs which involve simple tasks with instructions which are not detailed

or complex, where interpersonal contact was only incidental to work, involved few variables and little judgment, and the supervision required would be required to be simple, direct, and concrete. (Tr. 30–32). With the help of a VE, the ALJ determined that the Plaintiff would be unable to perform any of her past relevant work, but would be able to perform the representative occupations of

merchandise marker, call out operator, or routing clerk. (Tr. 32–24). The ALJ found Plaintiff had not been under a disability, as defined by the Act, from November 1, 2019, through March 20, 2021, the date of his decision. (Tr. 34). Plaintiff then requested a review of the hearing decision by the Appeals Council, which was denied on October 15, 2021. (Tr. 1–3). Subsequently, Plaintiff filed this action. (ECF No. 2). The parties have filed appeal briefs and this case is before the undersigned for report and recommendation pursuant to 28 USC §636 (b). (ECF Nos. 13, 14). The Court has reviewed the

entire transcript. The complete set of facts and arguments are presented in the parties’ briefs and are repeated here only to the extent necessary. II. Applicable Law: This court’s role is to determine whether substantial evidence supports the Commissioner’s findings. Vossen v. Astrue, 612 F.3d 1011, 1015 (8th Cir. 2010). Substantial evidence is less than a preponderance, but it is enough that a reasonable mind would find it adequate to support the Commissioner’s decision. Biestek v. Berryhill, 139 S.Ct. 1148, 1154 (2019). We must affirm the ALJ’s decision if the record contains substantial evidence to support it. Blackburn v. Colvin, 761 F.3d 853, 858 (8th Cir. 2014). As long as there is substantial evidence in the record that supports the Commissioner’s decision, the court may not reverse it

simply because substantial evidence exists in the record that would have supported a contrary outcome, or because the court would have decided the case differently. Miller v. Colvin, 784 F.3d 472, 477 (8th Cir. 2015). In other words, if after reviewing the record it is possible to draw two inconsistent positions from the evidence and one of those positions represents the findings of the ALJ, we must affirm the ALJ’s decision. Id. A claimant for Social Security disability benefits has the burden of proving his disability by establishing a physical or mental disability that has lasted at least one year and that prevents her from engaging in any substantial gainful activity. Pearsall v. Massanari, 274 F.3d 1211, 1217 (8th Cir. 2001); see also 42 U.S.C. § 423(d)(1)(A). The Act defines “physical or mental impairment” as “an impairment that results from anatomical, physiological, or psychological

abnormalities which are demonstrable by medically acceptable clinical and laboratory diagnostic techniques.” 42 U.S.C. § 423(d)(3). A Plaintiff must show that his or her disability, not simply his or her impairment, has lasted for at least twelve consecutive months. The Commissioner’s regulations require her to apply a five-step sequential evaluation process to each claim for disability benefits: (1) whether the claimant has engaged in substantial gainful activity since filing his or her claim; (2) whether the claimant has a severe physical and/or mental impairment or combination of impairments; (3) whether the impairment(s) meet or equal an impairment in the listings; (4) whether the impairment(s) prevent the claimant from doing past relevant work; and, (5) whether the claimant is able to perform other work in the national economy given his or her age, education, and experience. See 20 C.F.R. § 404.1520(a)(4). The fact finder only considers Plaintiff’s age, education, and work experience in light of his or her residual functional capacity if the final stage of the analysis is reached. 20 C.F.R. § 404.1520(a)(4)(v).

III. Discussion Plaintiff raises the following issues in this matter: 1) Whether the ALJ erred in failing to fully and fairly develop the record; 2) Whether the ALJ erred in assessing Plaintiff’s subjective complaints; and 3) Whether the ALJ erred in his residual functional capacity determination. (ECF No. 13). Of particular concern to the undersigned is the ALJ’s RFC determination. RFC is the most a person can do despite that person’s limitations. 20 C.F.R. § 404.1545(a)(1). It is assessed

using all relevant evidence in the record. Id. This includes medical records, observations of treating physicians and others, and the claimant’s own descriptions of her limitations. Guilliams v. Barnhart, 393 F.3d 798, 801 (8th Cir. 2005); Eichelberger v. Barnhart, 390 F.3d 584, 591 (8th Cir. 2004). Limitations resulting from symptoms such as pain are also factored into the assessment. 20 C.F.R.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Bastion v. Social Security Administration Commissioner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bastion-v-social-security-administration-commissioner-arwd-2023.