Burg v. O'Malley

CourtDistrict Court, E.D. Missouri
DecidedMarch 25, 2024
Docket4:23-cv-00329
StatusUnknown

This text of Burg v. O'Malley (Burg 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
Burg v. O'Malley, (E.D. Mo. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

KATHLEEN BURG, ) ) Plaintiff, ) ) v. ) Case No. 4:23-cv-00329-SRC ) MARTIN O’MALLEY, ) Commissioner of the Social Security ) Administration,1 ) ) Defendant. )

Memorandum and Order Kathleen Burg seeks judicial review, under 42 U.S.C. § 405(g), of the Commissioner of the Social Security Administration’s final decision denying her application for supplemental security income under Title XVI of the Social Security Act. 42 U.S.C. §§ 1381–85. The Court affirms the Commissioner’s decision. I. Procedural history In 2020, Burg protectively filed an application for supplemental security income. Tr. 101, 506. The Social Security Administration denied her application on initial review, Tr. 412–15, and on reconsideration, Tr. 425–26. Upon Burg’s request, an Administrative Law Judge held a hearing on January 24, 2022. Tr. 430–32; Tr. 325–75. Burg testified during the hearing. Tr. 332–67. The ALJ ultimately denied Burg’s application. Tr. 98–117. Burg sought review by the Appeals Council of the ALJ’s decision, but it denied Burg’s request. Tr. 1–6. The ALJ’s decision, therefore, is the final decision of the Commissioner that this Court reviews. See 20 C.F.R. §§ 404.900(a)(5), 416.1400(a)(5).

1 Martin O’Malley became the Commissioner of the Social Security Administration on December 20, 2023. II. Standard for determining disability under the Act Under the Social Security Act, an adult individual is disabled “if he is unable 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.” 42 U.S.C. § 1382c(a)(3)(B). The Commissioner follows a five-step evaluation 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. Id. at § 416.920(a)(4)(i). If the claimant is engaged in substantial gainful activity, the claimant is not disabled. Id. Second, if the claimant is not engaged in substantial gainful activity, the Commissioner

evaluates the evidence to determine whether the claimant has a severe “impairment[] [that] significantly limits [the claimant’s] physical or mental ability to do basic work activities.” Hurd v. Astrue, 621 F.3d 734, 738 (8th Cir. 2010) (quoting 20 C.F.R. § 416.920(c)); 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) (first citing Bowen v. Yuckert, 482 U.S. 137, 153 (1987); then citing id. at 158 (O’Connor, J., concurring); and then citing 20 C.F.R. § 404.1521(a)); 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). 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) (quoting Leckenby v. Astrue, 487 F.3d 626, 631 n.5 (8th Cir. 2007)); see also 20 C.F.R. § 416.945(a)(1). While 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,” 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) (quoting Moore v. Astrue, 572 F.3d 520, 523 (8th Cir. 2009)). 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) (first citing Myers v. Colvin, 721 F.3d 521, 526–27 (8th Cir. 2013); and then citing Perks v. Astrue, 687 F.3d 1086, 1092–93 (8th Cir. 2012)). 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[] 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 the Commissioner determines that 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). Finally, if the claimant’s RFC does not allow the claimant to perform past relevant work, the burden of producing evidence showing the claimant maintains the RFC to perform work that exists in significant numbers in the national economy shifts to the Commissioner. See Goff v.

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Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Hurd v. Astrue
621 F.3d 734 (Eighth Circuit, 2010)
Martise v. Astrue
641 F.3d 909 (Eighth Circuit, 2011)
McCoy v. Astrue
648 F.3d 605 (Eighth Circuit, 2011)
David Perks v. Michael J. Astrue
687 F.3d 1086 (Eighth Circuit, 2012)
Angela Myers v. Carolyn W. Colvin
721 F.3d 521 (Eighth Circuit, 2013)
Michael James Kamann v. Carolyn W. Colvin
721 F.3d 945 (Eighth Circuit, 2013)
Kirby v. Astrue
500 F.3d 705 (Eighth Circuit, 2007)
Moore v. Astrue
572 F.3d 520 (Eighth Circuit, 2009)
Katherine Johnson v. Carolyn Colvin
788 F.3d 870 (Eighth Circuit, 2015)
Carrie Andrews v. Carolyn W. Colvin
791 F.3d 923 (Eighth Circuit, 2015)
Tracy Milam v. Carolyn W. Colvin
794 F.3d 978 (Eighth Circuit, 2015)
Robert Crawford v. Carolyn W. Colvin
809 F.3d 404 (Eighth Circuit, 2015)
KKC v. Carolyn W. Colvin
818 F.3d 364 (Eighth Circuit, 2016)

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Burg v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/burg-v-omalley-moed-2024.