Buckley v. Kijakazi

CourtDistrict Court, E.D. Missouri
DecidedMarch 27, 2023
Docket4:22-cv-00100
StatusUnknown

This text of Buckley v. Kijakazi (Buckley v. Kijakazi) 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
Buckley v. Kijakazi, (E.D. Mo. 2023).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

CHARLENE C. BUCKLEY, ) ) Plaintiff, ) ) vs. ) Case No. 4:22-CV-100-ACL ) KILOLO KIJAKAZI, ) Acting Commissioner of Social Security ) Administration, ) ) Defendant. )

MEMORANDUM

Plaintiff Charlene Buckley brings this action pursuant to 42 U.S.C. § 405(g), seeking judicial review of the Social Security Administration Commissioner’s denial of her application for Disability Insurance Benefits (“DIB”) under Title II of the Social Security Act. An Administrative Law Judge (“ALJ”) found that, despite Buckley’ severe impairments, she was not disabled as she was capable of performing past relevant work. This matter is pending before the undersigned United States Magistrate Judge, with consent of the parties, pursuant to 28 U.S.C. § 636(c). A summary of the entire record is presented in the parties’ briefs and is repeated here only to the extent necessary. For the following reasons, the decision of the Commissioner will be affirmed. I. Procedural History Buckley filed her application for benefits on May 12, 2020. (Tr. 249.) She claimed she became unable to work on October 18, 2019, due to peripheral neuropathy in the bilateral upper extremities, bilateral cubital tunnel syndrome, bilateral median focal neuropathy at the wrists, Page 1 of 21 carpal tunnel syndrome, trigger fingers, arthritis in both hands, Dupuytren’s contracture, scapholunate ligament laxity, and muscle wasting. (Tr. 270.) Buckley was 56 years of age at her alleged onset of disability date. (Tr. 249.) Her application was denied initially. (Tr. 164.) Buckley’s claim was denied by an ALJ on April 22, 2021. (Tr. 109-22.) On December 1,

2021, the Appeals Council denied Buckley’s claim for review. (Tr. 1-4.) Thus, the decision of the ALJ stands as the final decision of the Commissioner. See 20 C.F.R. §§ 404.981, 416.1481. In this action, Buckley first argues that the ALJ erred by failing to “properly evaluate medical opinion evidence.” (Doc. 23 at 3.) She next argues that the “RFC assessment lacks rationale describing how the evidence supports the findings.” Id. at 5. Buckley also contends that the ALJ’s “pain/credibility evaluation is misleading and not supported by the record.” Id. at 7.

II. The ALJ’s Determination The ALJ first found that Buckley met the insured status requirements of the Social Security Act through December 31, 2022. (Tr. 111.) He stated that Buckley has not engaged in substantial gainful activity since his alleged onset date. (Tr. 112.) In addition, the ALJ concluded that Buckley had the following severe impairments: obesity, osteoarthritis, status post carpal tunnel release and ulnar nerve decompression, cubital tunnel syndrome, status post trigger finger releases, bilateral scapholunate ligamentous instability, neuropathy, and Dupuytren’s fasciitis. Id. The ALJ found that Buckley did not have an impairment or combination of

impairments that met or medically equaled the severity of one of the listed impairments. (Tr. 113.) As to Buckley’s RFC, the ALJ stated: Page 2 of 21 After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) except never climb ladders, ropes or scaffolds; never crawl; occasionally climb ramps and stairs, and balance as that term is used in the Selected Characteristics of Occupations; occasionally stoop, kneel and crouch; frequently reach, handle and finger; avoid concentrated exposure to extremes of heat and cold and excessive vibration; avoid all exposure to work place hazards such as hazardous machinery and unprotected heights.

(Tr. 114.) The ALJ found that Buckley was capable of performing her past relevant work as a case aide. (Tr. 121.) The ALJ therefore concluded that Buckley was not under a disability, as defined in the Social Security Act, from October 18, 2019, through the date of the decision. (Tr. 122.) The ALJ’s final decision reads as follows: Based on the application for a period of disability and disability insurance benefits protectively filed on May 12, 2020, the claimant is not disabled under sections 216(i) and 223(d) of the Social Security Act.

Id.

III. Applicable Law III.A. Standard of Review The decision of the Commissioner must be affirmed if it is supported by substantial evidence on the record as a whole. 42 U.S.C. § 405(g); Richardson v. Perales, 402 U.S. 389, 401 (1971); Estes v. Barnhart, 275 F.3d 722, 724 (8th Cir. 2002). Substantial evidence is less than a preponderance of the evidence, but enough that a reasonable person would find it adequate to support the conclusion. Johnson v. Apfel, 240 F.3d 1145, 1147 (8th Cir. 2001). This Page 3 of 21 “substantial evidence test,” however, is “more than a mere search of the record for evidence supporting the Commissioner’s findings.” Coleman v. Astrue, 498 F.3d 767, 770 (8th Cir. 2007) (internal quotation marks and citation omitted). “Substantial evidence on the record as a whole . . . requires a more scrutinizing analysis.” Id. (internal quotation marks and citations

omitted). To determine whether the Commissioner’s decision is supported by substantial evidence on the record as a whole, the Court must review the entire administrative record and consider: 1. The credibility findings made by the ALJ.

2. The plaintiff’s vocational factors.

3. The medical evidence from treating and consulting physicians.

4. The plaintiff’s subjective complaints relating to exertional and non-exertional activities and impairments.

5. Any corroboration by third parties of the plaintiff’s impairments.

6. The testimony of vocational experts when required which is based upon a proper hypothetical question which sets forth the claimant’s impairment.

Stewart v. Secretary of Health & Human Servs., 957 F.2d 581, 585-86 (8th Cir. 1992) (internal citations omitted). The Court must also consider any evidence which fairly detracts from the Commissioner’s decision. Coleman, 498 F.3d at 770; Warburton v. Apfel, 188 F.3d 1047, 1050 (8th Cir. 1999). However, even though two inconsistent conclusions may be drawn from the evidence, the Commissioner's findings may still be supported by substantial evidence on the record as a whole. Pearsall v. Massanari, 274 F.3d 1211, 1217 (8th Cir. 2001) (citing Young v. Page 4 of 21 Apfel, 221 F.3d 1065, 1068 (8th Cir. 2000)).

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Related

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)
Bertha Eichelberger v. Jo Anne B. Barnhart
390 F.3d 584 (Eighth Circuit, 2004)

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Buckley v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/buckley-v-kijakazi-moed-2023.