Carter v. O'Malley

CourtDistrict Court, E.D. Missouri
DecidedJanuary 16, 2025
Docket4:23-cv-01721
StatusUnknown

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

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

QUINA C., ) ) Plaintiff(s) ) ) vs. ) Case No. 4:23-CV-1721 SRW ) MARTIN O’MALLEY,1 ) 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. 18. Defendant filed a Brief in Support of the Answer. ECF No. 21. 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 affirm the Commissioner’s decision. I. Factual and Procedural Background On November 30, 2020, Plaintiff Quina C. protectively filed an application for supplemental security income under Title XVI, 42 U.S.C. §§ 1381, et seq., with an alleged onset

1 At the time this case was filed, Martin O’Malley was the Commissioner of Social Security. Carolyn Colvin became the Commissioner of Social Security on November 30, 2024. When a public officer ceases to hold office while an action is pending, the officer’s successor is automatically substituted as a party. Fed. R. Civ. P. 25(d). Later proceedings should be in the substituted party’s name, and the Court may order substitution at any time. Id. The Court will order the Clerk of Court to substitute Carolyn Colvin for Martin J. O’Malley in this matter. date of March 11, 2020. Tr. 536-43.2 Plaintiff’s applications were denied upon initial consideration and reconsideration. Tr. 467-72, 476-80. On July 15, 2021, she requested a hearing before an Administrative Law Judge (“ALJ”). Tr. 479-81. Plaintiff appeared for an in-person hearing, with the assistance of counsel, on October 6,

2022. Tr. 320-67. Plaintiff testified concerning her disability, daily activities, and functional limitations. Id. During the hearing, the ALJ received testimony from vocational expert (“VE”) Robin Pyle. Id. On February 3, 2023, the ALJ issued an unfavorable decision finding Plaintiff not disabled. Tr. 162-77. Plaintiff filed a request for review of the ALJ’s decision with the Appeals Council. Tr. 530-32. On November 2, 2023, the Appeals Council denied Plaintiff’s request for review. Tr. 1-7. Accordingly, the ALJ’s decision stands as the Commissioner’s final decision.3 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

2 The SSA’s paperwork contains a discrepancy as to the date Plaintiff filed her application. See Tr. 453 (listing the filing date as October 29, 2020), compare to Tr. 536 (listing the filing date as November 30, 2020). This discrepancy does not affect the Court’s decision.

3 The Court notes Plaintiff was previously determined to be disabled as of September 12, 2007. Tr. 373-84. On July 14, 2016, it was determined that Plaintiff was no longer disabled as of July 1, 2016. Tr. 385-401. Approximately two years later, Plaintiff refiled for SSI benefits alleging an onset date of September 28, 2018, which were denied upon the SSA’s determination that Plaintiff was not disabled. Tr. 407-23. 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.

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Related

Hurd v. Astrue
621 F.3d 734 (Eighth Circuit, 2010)
Martise v. Astrue
641 F.3d 909 (Eighth Circuit, 2011)
Buckner v. Astrue
646 F.3d 549 (Eighth Circuit, 2011)
Kirby v. Astrue
500 F.3d 705 (Eighth Circuit, 2007)
Casey v. Astrue
503 F.3d 687 (Eighth Circuit, 2007)
McNamara v. Astrue
590 F.3d 607 (Eighth Circuit, 2010)
Rick Whitman v. Carolyn W. Colvin
762 F.3d 701 (Eighth Circuit, 2014)
Bryce Mabry v. Carolyn W. Colvin
815 F.3d 386 (Eighth Circuit, 2016)
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)
Willie Boyd, Jr. v. Carolyn W. Colvin
831 F.3d 1015 (Eighth Circuit, 2016)

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