Cramer v. Commissioner of Social Security

District Court, W.D. North Carolina·Decided September 1, 2023·No. 1:22-cv-00191·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA ASHEVILLE DIVISION 1:22-cv-00191-WCM

AMBER MICHELLE CRAMER, ) ) Plaintiff, ) ) MEMORANDUM OPINION v. ) AND ORDER ) COMMISSIONER OF THE SOCIAL ) SECURITY ADMINISTRATION, ) ) Defendant. ) _______________________________ )

This matter is before the Court following the filing of Plaintiff’s Complaint Requesting Review of an Administrative Decision under the Social Security Act, and the parties’ briefs. (Docs. 1, 11, 13, 16).1 I. Procedural Background In November of 2018, Plaintiff Amber Michelle Cramer (“Plaintiff”) filed applications for disability insurance benefits and supplemental security income, alleging disability beginning on September 30, 2017. Transcript of the Administrative Record (“AR”) 322; 324-330; 331-342. On March 15, 2021, following an administrative hearing, an unfavorable decision was issued by an Administrative Law Judge (“ALJ”). AR 138-163.

1 The parties have consented to the disposition of this case by a United States Magistrate Judge. Doc. 15. Plaintiff challenged that decision, and the matter was remanded by the Appeals Council. See AR 164-168.

On December 29, 2021, following another administrative hearing, the ALJ issued an unfavorable decision. AR 10-38. That decision is the Commissioner’s final decision for purposes of this action. II. The ALJ’s Decision

The ALJ found that Plaintiff had the severe impairments of “obesity, fibromyalgia, rheumatoid arthritis, pulmonary embolism, depression, PTSD, anxiety, obstructive sleep apnea, and absence seizures.” AR 16. After determining that Plaintiff’s impairments did not meet or medically equal one

of the listed impairments, the ALJ found that Plaintiff had the residual functional capacity (“RFC”) to perform “light work” with additional physical and postural limitations. AR 18-19. Additionally, the ALJ found that Plaintiff had the RFC to:

perform simple and detailed work with occasional decision-making, frequent judgment required on the job; occasional changes in the work setting; and a reasoning level up to and including 3, which can be performed on a sustained basis 8 hours a day, 5 days a week, in two-hour increments with normal work breaks for an 8-hour workday. She requires a low- stress work environment, defined as non-production work, specifically no fast-paced work like an assembly line where one would have to produce a product in a high-speed manner. She can never have contact with the public and can have occasional contact with coworkers. AR 19. Applying this RFC, the ALJ found that Plaintiff had the ability to perform the representative jobs of “garment sorter,” “stock checker,” and “price

marker,” which exist in significant numbers in the national economy, such that Plaintiff was not disabled during the relevant period. AR 31-32. III. Plaintiff’s Allegations of Error Plaintiff contends that the ALJ failed to explain why the ALJ found a

state agency psychologist’s opinion to be persuasive but did not incorporate certain limitations set out in that opinion into Plaintiff’s RFC. Additionally, Plaintiff argues that one of the jobs relied upon by the ALJ is inconsistent with Plaintiff’s RFC.

IV. Standard of Review A claimant has the burden of proving that he or she suffers from a disability, which is defined as a medically determinable physical or mental impairment lasting at least 12 months that prevents the claimant from

engaging in substantial gainful activity. 20 C.F.R. §§ 404.1505; 416.905. The regulations require the Commissioner to evaluate each claim for benefits using a five-step sequential analysis. 20 C.F.R. §§ 404.1520; 416.920. The burden rests on the claimant through the first four steps to prove disability. Monroe v.

Colvin, 826 F.3d 176, 179 (4th Cir. 2016). If the claimant is successful at these steps, then the burden shifts to the Commissioner to prove at step five that the claimant can perform other work. Mascio v. Colvin, 780 F.3d 632, 635 (4th Cir. 2015); Monroe, 826 F.3d at 180.

Under 42 U.S.C. § 405(g), judicial review of a final decision of the Commissioner denying disability benefits is limited to whether substantial evidence exists in the record as a whole to support the Commissioner’s findings, and whether the Commissioner’s final decision applies the proper

legal standards. Hines v. Barnhart, 453 F.3d 559, 561 (4th Cir. 2006). When a federal district court reviews the Commissioner’s decision, it does not “re-weigh conflicting evidence, make credibility determinations, or substitute [its] judgment for that of the [Commissioner].” Craig v. Chater, 76 F.3d 585, 589

(4th Cir. 1996). Accordingly, the issue before the Court is not whether Plaintiff is disabled but, rather, whether the Commissioner’s decision that she is not disabled is supported by substantial evidence in the record and based on the correct application of the law. Id.

V. Discussion A. Plaintiff’s Mental Limitations The reasoning development scale of the Dictionary of Occupational Titles has six levels—Level 1 requires the least reasoning ability, while Level 6

requires the most reasoning ability. See DOT, App. C, 1991 WL 688702. A “reasoning level of one” requires the ability to “[a]pply commonsense understanding to carry out simple one- or two-step instructions” and “[d]eal with standardized situations with occasional or no variables in or from these situations encountered on the job.” DOT, Appendix C, 1991 WL 688702. A

“reasoning level of two” requires the ability to “[a]pply commonsense understanding to carry out detailed but uninvolved written or oral instructions” and to “[d]eal with problems involving a few concrete variables in or from standardized situations.” Id. A “reasoning level of three” requires the

ability to apply “commonsense understanding to carry out instructions furnished in written, oral, or diagrammatic form” and to “[d]eal with problems involving several concrete variables in or from standardized situations.” Id. Here, on initial review, state agency consultant Nicole Mannis, Psy.D.,

provided an opinion regarding Plaintiff’s mental limitations. AR 94-96. Dr. Mannis’ assessment indicated that Plaintiff had moderate limitations with respect to understanding and memory, concentration and persistence, and social interaction. AR 95-96. Regarding Plaintiff’s understanding and memory

limitations specifically, Dr. Mannis concluded that Plaintiff “may have some difficulty with detailed instructions” but appeared “capable of completing simple 1-2 step instructions.” AR 94. Plaintiff contends that, based on Dr. Mannis’ opinion, the ALJ should

have included in the RFC a limitation to “simple 1-2 step instructions” and that the ALJ’s omission of this limitation is “significant because a limitation to one to two step instructions would preclude each of the reasoning level two jobs the ALJ cited” as a basis for denial of Plaintiff’s social security claim. Doc. 11 at 2.

In his decision, the ALJ explained that he found Dr.

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