Baumgarden v. Dudek

CourtDistrict Court, W.D. Missouri
DecidedFebruary 26, 2025
Docket4:24-cv-00035
StatusUnknown

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

Bluebook
Baumgarden v. Dudek, (W.D. Mo. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION

DEANNA L. BAUMGARDEN, ) ) Plaintiff, ) ) v. ) No. 4:24-CV-00035-DGK-SSA ) LEE DUDEK, ) Acting Commissioner of Social Security, ) ) Defendant. )

ORDER AFFIRMING THE COMMISSIONER’S DECISION

This case arises from the Commissioner of Social Security’s (“the Commissioner”) denial of Plaintiff Deanna L. Baumgarden’s application for disability insurance benefits (“DIBs”) under Title II of the Social Security Act (“the Act”), 42 U.S.C. §§ 401–434. The Administrative Law Judge (“ALJ”) found Plaintiff had several severe impairments, including fibromyalgia, migraines, umbilical hernia, and status post small bowel resection of the ileum. But the ALJ found that she retained the residual functional capacity (“RFC”) to perform light work with certain additional limitations, including work as a router, storage facility rental clerk, and cashier. After carefully reviewing the record and the parties’ arguments, the Court finds the ALJ’s opinion is supported by substantial evidence on the record as a whole. The Commissioner’s decision is AFFIRMED. Procedural and Factual Background The complete facts and arguments are presented in the parties’ briefs and are repeated here only to the extent necessary. Plaintiff applied for DIBs on June 15, 2021, alleging a disability onset date of May 20, 2021. The Commissioner denied the application at the initial claim level, and Plaintiff appealed the case to the ALJ. After holding a hearing, the ALJ found Plaintiff was not disabled. The Appeals Council denied Plaintiff’s request for review on November 8, 2023, leaving the ALJ’s decision as the Commissioner’s final decision. Judicial review is now appropriate under 42 U.S.C. § 405(g).

Standard of Review A federal court’s review of the Commissioner’s decision to deny disability benefits is limited to determining whether the Commissioner’s findings are supported by substantial evidence on the record as a whole and whether the ALJ committed any legal errors. Igo v. Colvin, 839 F.3d 724, 728 (8th Cir. 2016). Substantial evidence is less than a preponderance but is enough evidence that a reasonable mind would find it sufficient to support the Commissioner’s decision. Id. In making this assessment, the court considers evidence that detracts from the Commissioner’s decision, as well as evidence that supports it. Id. The Court must “defer heavily” to the Commissioner’s findings and conclusions. Wright v. Colvin, 789 F.3d 847, 852 (8th Cir. 2015); see Biestek v. Berryhill, 139 S. Ct. 1148, 1157 (2019) (noting the substantial evidence standard of

review “defers to the presiding ALJ, who has seen the hearing up close.”). The Court may reverse the Commissioner’s decision only if it falls outside of the available zone of choice; a decision is not outside this zone simply because the evidence also points to an alternate outcome. Buckner v. Astrue, 646 F.3d 549, 556 (8th Cir. 2011). Discussion The Commissioner follows a five-step sequential evaluation process1 to determine whether a claimant is disabled, that is, unable to engage in any substantial gainful activity by reason of a medically determinable impairment that has lasted or can be expected to last for a continuous

period of at least twelve months. 42 U.S.C. § 423(d)(1)(A). Here, Plaintiff challenges the ALJ’s actions at Step Four by arguing that the ALJ erred in: (1) assessing the physical components of Plaintiff’s RFC; and (2) assessing the mental components of Plaintiff’s RFC. Before delving into the numerous, specific arguments on these fronts, the Court notes a unifying deficiency across most arguments. Plaintiff repeatedly atomizes and cherry picks record evidence that supports a finding of disability, while ignoring or downplaying the evidence that supported the ALJ’s decision. These arguments not only mischaracterize the record and the ALJ’s well-supported and thorough decision, but they also invite the Court to do what it cannot: “reweigh the evidence presented to the ALJ or try the issue in this case de novo.” Dols v. Saul, 931 F.3d

741, 746 (8th Cir. 2019) (internal quotation marks omitted). Plaintiff’s kitchen sink approach also forces the Commissioner to expend considerable time and resources scouring the record and caselaw to refute her meritless arguments. As best the Court can tell, this appears to be an attempt

1 “The five-step sequence involves determining whether (1) a claimant’s work activity, if any, amounts to substantial gainful activity; (2) [her] impairments, alone or combined, are medically severe; (3) [her] severe impairments meet or medically equal a listed impairment; (4) [her] residual functional capacity precludes [her] past relevant work; and (5) [her] residual functional capacity permits an adjustment to any other work. The evaluation process ends if a determination of disabled or not disabled can be made at any step.” Kemp ex rel. Kemp v. Colvin, 743 F.3d 630, 632 n.1 (8th Cir. 2014); see 20 C.F.R. §§ 404.1520(a)–(g). Through Step Four of the analysis the claimant bears the burden of showing that she is disabled. After the analysis reaches Step Five, the burden shifts to the Commissioner to show that there are other jobs in the economy that the claimant can perform. King v. Astrue, 564 F.3d 978, 979 n.2 (8th Cir. 2009). to overwhelm the Commissioner and get him to agree to a remand rather than respond to Plaintiff’s voluminous arguments. If Plaintiff’s counsel takes this approach in future cases, the Court will summarily affirm the Commissioner’s decision and may also impose sanctions under Federal Rule of Civil Procedure

11, 28 U.S.C. § 1927, and/or the Court’s inherent authority. All arguments should be targeted to meritorious issues that are supported by the caselaw and factual record. I. Substantial evidence supports the ALJ’s RFC formulation with respect to Plaintiff’s physical limitations.

In a meandering and unstructured set of arguments,2 Plaintiff contends the ALJ erred in various ways in assessing the physical components of her RFC. Defendant counters each point with controlling caselaw and record evidence. None of Plaintiff’s arguments have any merit. First, substantial evidence supports the ALJ’s finding that Plaintiff’s fibromyalgia did not cause disabling limitations. See R. at 25, 336, 355, 501–02, 508–09, 558, 563, 569, 575, 586, 592, 598, 604, 610, 616, 622, 628, 709, 733; see also Swarthout v. Kijakazi, 35 F.4th 608, 611 (8th Cir. 2022) (“Several other reports of examinations include unremarkable findings. As we have said before, that working may cause discomfort does not dictate a finding of disability, and not every diagnosis of fibromyalgia warrants a finding that a claimant is disabled.” (internal quotation marks omitted)).

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Baumgarden v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baumgarden-v-dudek-mowd-2025.