Brooks v. O'Malley

CourtDistrict Court, E.D. Missouri
DecidedMarch 27, 2025
Docket4:24-cv-00364
StatusUnknown

This text of Brooks v. O'Malley (Brooks 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
Brooks v. O'Malley, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

BRIDGET BROOKS, ) ) Plaintiff, ) ) v. ) No. 4:24-CV-364 HEA ) LELAND DUDEK, Acting ) Commissioner of Social Security,1 ) ) Defendant. )

OPINION, MEMORANDUM AND ORDER Plaintiff Bridget Brooks brings this action pursuant to 42 U.S.C. § 405(g) for judicial review of the Commissioner’s final decision denying her application for disability insurance benefits (DIB) under Title II of the Social Security Act, 42 U.S.C. §§ 401, et seq. A summary of the record is presented in the parties’ briefs and is repeated here only to the extent necessary. The Court has reviewed the filings and the administrative record as a whole, which includes the hearing transcript and medical evidence. For the following reasons, the decision of the Commissioner is reversed.

1Leland Dudek became the Acting Commissioner of Social Security on February 18, 2025. Therefore, pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Leland Dudek should be substituted for Martin O’Malley as the defendant in this suit. No further action need be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g). I. Procedural History On June 18, 2021, Plaintiff protectively filed her application for DIB.

Plaintiff, who was born in December 1968, alleged she had been unable to work since January 1, 2019, due to blindness/low vision, degenerative lumbar arthritis, degenerative disc disease, high blood pressure, “trouble walking without pain,”

migraines, and sleep apnea (Tr. 223). Plaintiff’s application was denied on initial consideration, and she requested a hearing before an Administrative Law Judge (“ALJ”). Plaintiff and counsel appeared for a hearing on October 14, 2023. (Tr. 34- 67). Plaintiff testified concerning her disability, daily activities, functional

limitations, and past work. Id. The ALJ also received testimony from vocational expert (“VE”) John Dolan. Id. On March 9, 2023, the ALJ issued an unfavorable decision finding Plaintiff not disabled. (Tr. 15-27). Plaintiff filed a request for review

of the ALJ’s decision with the Appeals Council. On January 11, 2024, the Appeals Council denied Plaintiff’s request for review. (Tr. 1-6). Plaintiff has exhausted her administrative remedies, and the ALJ’s decision stands as the final decision of the Commissioner subject to judicial review. See 42 U.S.C. §§ 405(g), 1383(c)(3).

In this action for judicial review, Plaintiff claims the ALJ committed reversible error in his decision. Plaintiff requests that the Commissioner’s decision be reversed, and the matter remanded for an award of benefits or for further evaluation. II. Legal Standard To be eligible for DIB under the Social Security Act, plaintiff must prove she

is disabled. Pearsall v. Massanari, 274 F.3d 1211, 1217 (8th Cir. 2001); Baker v. Sec'y of Health & Hum. Servs., 955 F.2d 552, 555 (8th Cir. 1992). The Social Security Act defines disability 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 12 months.” 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). An individual will be declared disabled “only if his [or her] physical

or mental impairment or impairments are of such severity that he [or she] is not only unable to do his [or her] previous work but cannot, considering his [or her] age, education, and work experience, engage in any other kind of substantial gainful work

which exists in the national economy.” 42 U.S.C. §§ 423(d)(2)(A), 1382c(a)(3)(B). To determine whether a claimant is disabled, the Commissioner engages in a five-step evaluation process. See 20 C.F.R. §§ 404.1520, 416.920; Bowen v. Yuckert, 482 U.S. 137, 140-42 (1987). The Commissioner begins by deciding

whether the claimant is engaged in substantial gainful activity. If the claimant is working, disability benefits are denied. Second, the Commissioner decides whether the claimant has a “severe” impairment or combination of impairments, meaning

that which significantly limits his or her ability to do basic work activities. If the claimant’s impairment is not severe, then he or she is not disabled. 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 20 C.F.R., Part 404, Subpart P, Appendix 1, the claimant is considered disabled, regardless of age, education, and work

experience. 20 C.F.R. §§ 416.920(a)(4)(iii), (d). At the fourth step, if the claimant’s impairment is severe but does not meet or equal one of the presumptively disabling impairments, the Commissioner assesses whether the claimant retains the 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).

Ultimately, the claimant is responsible for providing evidence relating to his or her 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). In the fifth step, the Commissioner evaluates various factors to determine whether the claimant is capable of performing any other work in the economy. If

the claimant’s RFC does not allow the claimant to perform past relevant work, the burden of production shifts to the Commissioner to show the claimant maintains the RFC to perform work that exists in significant numbers in the national

economy. See Brock v. Astrue, 674 F.3d 1062

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

Related

Halverson v. Astrue
600 F.3d 922 (Eighth Circuit, 2010)
Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Martise v. Astrue
641 F.3d 909 (Eighth Circuit, 2011)
Brock v. Astrue
674 F.3d 1062 (Eighth Circuit, 2012)
Steed v. Astrue
524 F.3d 872 (Eighth Circuit, 2008)
Coleman v. Astrue
498 F.3d 767 (Eighth Circuit, 2007)
Ford v. Astrue
518 F.3d 979 (Eighth Circuit, 2008)
KKC v. Carolyn W. Colvin
818 F.3d 364 (Eighth Circuit, 2016)
Marcus Hensley v. Carolyn W. Colvin
829 F.3d 926 (Eighth Circuit, 2016)
Lacey Reece v. Carolyn Colvin
834 F.3d 904 (Eighth Circuit, 2016)
Rhonda Gann v. Nancy A. Berryhill
864 F.3d 947 (Eighth Circuit, 2017)
Carolyn Combs v. Nancy A. Berryhill
878 F.3d 642 (Eighth Circuit, 2017)

Cite This Page — Counsel Stack

Bluebook (online)
Brooks v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/brooks-v-omalley-moed-2025.