Bossio-Haines v. O'Malley

CourtDistrict Court, E.D. Missouri
DecidedOctober 17, 2023
Docket4:22-cv-01335
StatusUnknown

This text of Bossio-Haines v. O'Malley (Bossio-Haines v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bossio-Haines v. O'Malley, (E.D. Mo. 2023).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

MALISSA BOSSIO-HAINES, ) ) Plaintiff(s), ) ) vs. ) Case No. 4:22-CV-1335 SRW ) KILOLO KIJAKAZI, ) Commissioner of Social Security ) Administration, ) ) Defendant(s). )

MEMORANDUM AND ORDER This matter is before the Court on review of an adverse ruling by the Social Security Administration. The Court has jurisdiction over the subject matter of this action under 42 U.S.C. § 405(g). The parties consented to the exercise of authority by the United States Magistrate Judge pursuant to 28 U.S.C. § 636(c). Plaintiff filed a Brief in support of the Complaint. ECF No. 13. Defendant filed a Brief in Support of the Answer. ECF No. 14. Plaintiff filed a Reply. ECF No. 15. The Court has reviewed the parties’ briefs and the entire administrative record, including the transcripts and medical evidence. Based on the following, the Court will reverse the Commissioner’s denial of Plaintiff’s application and remand the case for further proceedings. I. Factual and Procedural Background On September 17, 2020 and November 24, 2020, respectively, Plaintiff Malissa Bossio- Haines protectively filed applications for disability insurance benefits under Title II, 42 U.S.C. §§ 401, et seq., and supplemental security income under Title XVI, 42 U.S.C. §§ 1381, et seq. Tr. 308-14, 317-23. Plaintiff’s application was denied on initial consideration and reconsideration. Tr. 191-202, 205-12. On November 15, 2021, she requested a hearing before an Administrative Law Judge (“ALJ”). Tr. 223-24. Plaintiff appeared for a telephonic hearing, with the assistance of counsel, on April 4, 2022. Tr. 43-74. Plaintiff testified concerning her disability, daily activities, functional

limitations, and past work. Id. The ALJ also received testimony from vocational expert (“VE”) Delores Gonzalez. Id. On June 1, 2022, the ALJ issued an unfavorable decision finding Plaintiff not disabled. Tr. 7-36. Plaintiff filed a request for review of the ALJ’s decision with the Appeals Council. Tr. 303-04. On October 18, 2022, the Appeals Council denied Plaintiff’s request for review. Tr. 1-6. Accordingly, the ALJ’s decision stands as the Commissioner’s final decision. With regard to Plaintiff’s testimony, medical records, and work history, the Court accepts the facts as presented in the parties’ respective statements of facts and responses. The Court will discuss specific facts relevant to the parties’ arguments as needed in the discussion below. II. Legal Standard

A disability is defined as the inability “to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than twelve months.” 42 U.S.C. § 1382c(a)(3)(A). A claimant has a disability “only if his physical or mental impairment or impairments are of such severity that he is not only unable to do his previous work but cannot, considering his age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy[.]” § 1382c(a)(3)(B). The Commissioner follows a five-step sequential process when evaluating whether the claimant has a disability. 20 C.F.R. § 416.920(a)(1). First, the Commissioner considers the claimant’s work activity. If the claimant is engaged in substantial gainful activity, the claimant is not disabled. 20 C.F.R. § 416.920(a)(4)(i).

Second, if the claimant is not engaged in substantial gainful activity, the Commissioner looks to see whether the claimant has a severe impairment “which significantly limits claimant’s physical or mental ability to do basic work activities.” Hurd v. Astrue, 621 F.3d 734, 738 (8th Cir. 2010); see also 20 C.F.R. § 416.920(a)(4)(ii). “An impairment is not severe if it amounts only to a slight abnormality that would not significantly limit the claimant’s physical or mental ability to do basic work activities.” Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007); see also 20 C.F.R. §§ 416.920(c), 416.920a(d). Third, if the claimant has a severe impairment, the Commissioner considers the impairment’s medical severity. If the impairment meets or equals one of the presumptively disabling impairments listed in the regulations, the claimant is considered disabled, regardless of

age, education, and work experience. 20 C.F.R. §§ 416.920(a)(4)(iii), (d). Fourth, if the claimant’s impairment is severe, but it does not meet or equal one of the presumptively disabling impairments, the Commissioner assesses whether the claimant retains the “residual functional capacity” (“RFC”) to perform his or her past relevant work. 20 C.F.R. §§ 416.920(a)(4)(iv), 416.945(a)(5)(i). An RFC is “defined as the most a claimant can still do despite his or her physical or mental limitations.” Martise v. Astrue, 641 F.3d 909, 923 (8th Cir. 2011); see also 20 C.F.R. § 416.945(a)(1). While an RFC must be based “on all relevant evidence, including the medical records, observations of treating physicians and others, and an individual’s own description of his limitations,” an RFC is nonetheless an “administrative assessment”—not a medical assessment—and therefore “it is the responsibility of the ALJ, not a physician, to determine a claimant’s RFC.” Boyd v. Colvin, 831 F.3d 1015, 1020 (8th Cir. 2016). Thus, “there is no requirement that an RFC finding be supported by a specific medical opinion.” Hensley v. Colvin, 829 F.3d 926, 932 (8th Cir. 2016). Ultimately, the claimant is responsible for

providing evidence relating to his RFC, and the Commissioner is responsible for developing the claimant’s “complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help [the claimant] get medical reports from [the claimant’s] own medical sources.” 20 C.F.R. § 416.945(a)(3). If, upon the findings of the ALJ, it is determined the claimant retains the RFC to perform past relevant work, he or she is not disabled. 20 C.F.R. § 416.920(a)(4)(iv).

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Related

Hurd v. Astrue
621 F.3d 734 (Eighth Circuit, 2010)
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Clinton Hiler v. Michael Astrue
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Kirby v. Astrue
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TAYLOR EX REL. MCKINNIES v. Barnhart
333 F. Supp. 2d 846 (E.D. Missouri, 2004)
KKC v. Carolyn W. Colvin
818 F.3d 364 (Eighth Circuit, 2016)
Marcus Hensley v. Carolyn W. Colvin
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Willie Boyd, Jr. v. Carolyn W. Colvin
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Wilson v. Colvin
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Bossio-Haines v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bossio-haines-v-omalley-moed-2023.