Chastain v. Kijakazi

CourtDistrict Court, W.D. Missouri
DecidedMay 15, 2023
Docket6:22-cv-03182
StatusUnknown

This text of Chastain v. Kijakazi (Chastain v. Kijakazi) is published on Counsel Stack Legal Research, covering District Court, W.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chastain v. Kijakazi, (W.D. Mo. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI SOUTHERN DIVISION ERIC FARRELL CHASTAIN, ) ) Plaintiff, ) ) v. ) No. 6:22-CV-03182-WJE ) KILOLO KIJAKAZI, ) Acting Commissioner of Social Security, ) ) Defendant. )

ORDER For a second time, Plaintiff Eric Farrell Chastain seeks judicial review of a final administrative decision of the Acting Commissioner of Social Security (“Acting Commissioner”) denying his claims for disability insurance benefits (“DIB”) under Title II of the Social Security Act (“SSA”), 42 U.S.C. §§ 401–434, and supplemental security income (“SSI”) under Title XVI of the SSA, 42 U.S.C. §§ 1382–1385. This matter returns to this Court after its initial reverse and remand because the Administrative Law Judge (“ALJ”) again found that although Mr. Chastain had several severe and non-severe impairments, he retained the residual functional capacity (“RFC”) to perform light work with some limitations. After carefully reviewing the record and the parties’ arguments in this second instance, the Court finds the ALJ’s opinion is supported by substantial evidence on the record as a whole. Therefore, the Acting Commissioner’s decision is AFFIRMED. I. Background Mr. Chastain protectively filed claims for DIB and SSI1 on March 21, 2017. (AR 51). He alleged a disability onset date of January 7, 2016, due to double hernia pain, a foot rash, arthritis

1 Mr. Chastain filed a subsequent claim for SSI on December 18, 2019. (AR 824). The ALJ then consolidated his claims for SSI. (Id.). in his hands, swelling in his right index finger, left thumb muscle, and depression. (Id. 217, 824). His claims were initially denied on August 17, 2017. (Id. 51). He filed a written request for a hearing which was held on January 29, 2019. (Id.). On May 6, 2019, the ALJ denied Mr. Chastain’s claims. (Id. 48). Following the ALJ’s decision, Mr. Chastain filed an appeal with the Appeals Council. (Id. 166–67). The Appeals Council denied his request for review, leaving the ALJ’s

decision as the final decision of the Acting Commissioner. (Id. 1–3). Mr. Chastain then appealed to this Court, and the Court remanded the Acting Commissioner’s decision for further consideration and development of the record.2 (Id. 949–51, 954–58). On July 13, 2020, the Appeals Council remanded his claims back to the ALJ. (Id. 960–62). Upon remand, a new hearing was held on February 16, 2021. (Id. 824. 888). On May 3, 2021, the ALJ denied Mr. Chastain’s claims. (Id. 821–23). The ALJ determined that although Mr. Chastain had severe impairments, none of them met or exceeded a listed impairment. (Id. 828–32). The ALJ also determined that Mr. Chastain had an RFC to perform light work with certain limitations, including:

He can lift and/or carry 20 pounds occasionally and 10 pounds frequently. The claimant can stand and/or walk for six hours in an eight-hour workday. He can sit for six hours in an eight-hour workday. The claimant can occasionally handle and finger bilaterally. He can occasionally reach overhead with the upper right extremity. The claimant can have occasional exposure to cold, wetness, vibration, and hazards, such as heights and moving machinery. The claimant has the ability and concentration for simple tasks involving routine work-related decisions with simple judgment and only occasional work place changes. The claimant can have occasional contact with the public, coworkers, and supervisors.

(Id. 833). During the hearing on May 3, 2021, the ALJ asked a vocational expert (“VE”) whether a hypothetical individual with Mr. Chastain’s age, education, and work experience, along with the RFC identified above, would be capable of working. (Id. 843, 915, 917). The VE testified that such

2 This prior appeal and subsequent remand addressed issues not pertinent here. (AR 954–58; Doc. 10 at 9, fn. 1). an individual could perform work as a bakery worker, fruit distributor, or thermal-surfacing- machine operator (Id. 843, 915, 917–19). Following the ALJ’s decision, Mr. Chastain filed an appeal with the Appeals Council. (Id. 1027–28). The Appeals Council denied his request for review, leaving the ALJ’s decision as the final decision of the Acting Commissioner. (Id. 814–17). Because Mr. Chastain has exhausted all

administrative remedies, judicial review is now appropriate under 42 U.S.C. §§ 405(g) and 1383(c)(3).

II. Disability Determination and the Burden of Proof The burden of establishing a disability as defined by the SSA in 42 U.S.C. §§ 423(d) and 1382c(a) rests on the claimant. Kirby v. Astrue, 500 F.3d 705, 707–08 (8th Cir. 2007). The SSA has established a five-step, sequential evaluation process for appraising whether a claimant is disabled and benefit-eligible. 20 C.F.R. §§ 404.1520, 416.920; see also Sloan v. Saul, 933 F.3d 946, 949 (8th Cir. 2019). The Commissioner must evaluate:

(1) whether the claimant is presently engaged in a substantial gainful activity; (2) whether the claimant has a severe impairment that significantly limits the claimant’s physical or mental ability to perform basic work activities; (3) whether the claimant has an impairment that meets or equals a presumptively disabling impairment listed in the regulations; (4) whether the claimant has the residual functional capacity to perform his or her past relevant work; and (5) if the claimant cannot perform the past work, the burden shifts to the Commissioner to prove that there are other jobs in the national economy that the claimant can perform.

Dixon v. Barnhart, 353 F.3d 602, 605 (8th Cir. 2003) (citation omitted); see also Perks v. Astrue, 687 F.3d 1086, 1091–92 (8th Cir. 2012). III. Standard of Review The Eighth Circuit requires the reviewing court to “determine whether the Commissioner’s findings are supported by substantial evidence on the record as a whole.” Baker v. Barnhart, 457 F.3d 882, 892 (8th Cir. 2006) (quotation omitted). “Substantial evidence is less than a preponderance [of the evidence],” in that it merely requires that a reasonable person find the

evidence adequate to support the Commissioner’s decision. Id. (quotation omitted); see also Cox v. Barnhart, 345 F.3d 606, 608 (8th Cir. 2003). The reviewing court must “defer heavily” to the Commissioner’s findings and conclusions. Wright v. Colvin, 789 F.3d 847, 852 (8th Cir. 2015); see also Biestek v. Berryhill, 139 S. Ct. 1148, 1157 (2019) (noting the substantial evidence standard of review “defers to the presiding ALJ, who has seen the hearing up close”).

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Bluebook (online)
Chastain v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chastain-v-kijakazi-mowd-2023.