Cooper v. Saul

CourtDistrict Court, E.D. Missouri
DecidedMarch 25, 2022
Docket4:20-cv-01458
StatusUnknown

This text of Cooper v. Saul (Cooper v. Saul) 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.

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Cooper v. Saul, (E.D. Mo. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

LINDA D. COOPER, ) ) Plaintiff, ) ) v. ) No. 4:20 CV 1458 RWS ) KILOLO KIJAKAZI1, ) Acting Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM AND ORDER

Plaintiff Linda D. Cooper brings this action pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3) seeking judicial review of the Commissioner’s decision denying her application for disability benefits under the Social Security Disability Insurance Program (SSDI), Title II of the Social Security Act, 42 U.S.C. §§ 401- 434 and for benefits under the Supplemental Security Income Program (SSI), Title XVI of the Social Security Act, 42 U.S.C. §§ 1381-1385. For the reasons set forth below, I will affirm the decision of the Commissioner.

1 Kilolo Kijakazi became the Acting Commissioner of Social Security on July 9, 2021. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Kilolo Kijakazi should be substituted for Andrew Saul 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). Procedural History Plaintiff Linda Cooper was born on October 1, 1972. She is currently 49

years old. She dropped out of high school in the 12th grade and has not earned a General Education Diploma (GED).2 In the past several years before she applied for disability benefits Cooper worked as a temporary office worker, in fast-food

restaurants, and as a store clerk. In the three years before she applied for benefits Cooper earned less than $10,000 per year at these jobs. (Tr. 148-152.) The last job Cooper held was as a stocker and cashier at a Dollar General store. (Tr. 30.) Her employment was terminated in August 2018, because her right hip hurt so

badly that she was unable to perform her job duties. (Tr. 30-31.) Cooper protectively filed a Title II application for a period of disability and disability insurance benefits and a Title XVI application for supplemental security

income on September 5, 2018. (Tr. 10, 135.) She alleges that she became disabled beginning August 26, 2018, because of severe osteoarthritis in her right hip, walking with a limp, and the need for a possible hip replacement. (Tr. 44, 55.) Plaintiff’s applications were initially denied on December 6, 2018. (Tr. 53,

64.) After a hearing before an Administrative Law Judge (ALJ) on October 17, 2019, the ALJ issued a decision denying benefits on January 21, 2019. (Tr. 7-18.)

2 GED actually stands for General Education Development Test, however the initials have been used in the vernacular to mean a Graduate Equivalency Degree or a General Educational Diploma. https://ged.com/blog/what- is-a-ged/ On September 10, 2020, the Appeals Council denied plaintiff’s request for review. (Tr. 1-6.) The ALJ’s decision is now the final decision of the Commissioner. 42

U.S.C. §§ 405(g) and 1383(c)(3). In this action for judicial review, Cooper contends that the ALJ failed to properly evaluate Cooper’s subjective complaints regarding her physical and daily

activities limitations in determining her residual functional capacity (RFC). Cooper requests that I reverse the Commissioner’s final decision and remand the matter for the ALJ to conduct a “proper evaluation” of Cooper’s activities of daily living. For the reasons that follow, I will deny Cooper’s request to remand this

matter for further proceedings. Medical Records and Other Evidence Before the ALJ With respect to the medical records and other evidence of record, I adopt

Cooper’s recitation of facts (ECF # 26). Additional specific facts will be discussed as needed to address the parties’ arguments. Discussion A. Legal Standard

To be eligible for disability insurance benefits under the Social Security Act, a plaintiff must prove that he is disabled. Pearsall v. Massanari, 274 F.3d 1211, 1217 (8th Cir. 2001); Baker v. Secretary of Health & Human 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). An individual will be declared disabled “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. § 423(d)(2)(A). To determine whether a claimant is disabled, the Commissioner engages in a

five-step evaluation process. See 20 C.F.R. § 404.1520; Bowen v. Yuckert, 482 U.S. 137, 140-42 (1987). The Commissioner begins by deciding whether the claimant is engaged in substantial gainful activity (SGA).3 If not, the disability

analysis proceeds to the second step. In this step the Commissioner decides whether the claimant has a “severe” impairment or combination of impairments, meaning that which significantly limits his ability to do basic work activities. If the claimant’s impairment(s) is not severe, then he is not disabled and the analysis

3 “Substantial gainful activity (SGA) is defined as work activity that is both substantial and gainful. ‘Substantial work activity’ is work activity that involves doing significant physical or mental activities (20 CFR 404.1572(a) and 416.972(a)). ‘Gainful work activity’ is work that is usually done for pay or profit, whether or not a profit is realized (20 CFR 404.1572(b) and 416.972(b)). Generally, if an individual has earnings from employment or self- employment above a specific level set out in the regulations, it is presumed that he has demonstrated the ability to engage in SGA (20 CFR 404.1574, 404.1575, 416.974, and 416.975). If an individual engages in SGA, he is not disabled regardless of how severe his physical or mental impairments are and regardless of his age, education, and work experience.” (Tr. 11.) ends. If the claimant has a severe impairment the Commissioner then proceeds to the third step and determines whether claimant’s impairment(s) meets or equals

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