Crick v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedApril 22, 2025
Docket4:24-cv-01026
StatusUnknown

This text of Crick v. Social Security Administration (Crick v. Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, E.D. Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Crick v. Social Security Administration, (E.D. Ark. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

KIMBERLY LYNN CRICK PLAINTIFF

V. NO. 4:24CV01026-KGB-PSH

LELAND DUDEK, ACTING COMMISSIONER of the SOCIAL SECURITY ADMINISTRATION DEFENDANT

RECOMMENDED DISPOSITION

This Recommended Disposition (“Recommendation”) has been sent to Chief United States District Judge Kristine G. Baker. Either party may file written objections to this Recommendation. If objections are filed, they should be specific and should include the factual or legal basis for the objection. To be considered, objections must be received in the office of the Court Clerk within 14 days of this Recommendation. If no objections are filed, Chief Judge Baker can adopt this Recommendation without independently reviewing the record. By not objecting, parties may also waive the right to appeal questions of fact. I. Introduction:

Plaintiff, Kimberly Lynn Crick (“Ms. Crick”), filed an application for Title II disability and disability insurance benefits on January 19, 2022. (Tr. at 74). In the application, Ms. Crick alleged disability beginning on July 31, 2021. Id. The

1 application was denied initially and upon reconsideration. Id. After conducting a hearing, an Administrative Law Judge (AALJ@) found that Ms. Crick was not

disabled. (Tr. at 74-89). On October 31, 2024, the Appeals Council, having discussed new evidence provided by Ms. Crick, denied her request for review of the hearing decision. (Tr. at 1-6). This decision stands as the final decision of the Commissioner,

and Ms. Crick has requested judicial review. For the reasons stated below, this Court should affirm the ALJ’s decision and enter judgment for Defendant. II. The Commissioner=s Decision:

The ALJ found that Ms. Crick, who was 51 years old on the alleged onset date, meets the insured status requirement of the Social Security Act through March 31, 2026. (Tr. at 77, 87). The ALJ next found that Ms. Crick had not engaged in

substantial gainful activity since the alleged onset date of July 31, 2021.1 Id. At Step Two, the ALJ found that Ms. Crick had the following severe impairments: spinal stenosis with scoliosis and bilateral lower extremity neuropathy, carpal tunnel

1 An ALJ must follow the required five-step sequence to determine: (1) whether the claimant was engaged in substantial gainful activity; (2) if not, whether the claimant had a severe impairment; (3) if so, whether the impairment (or combination of impairments) met or equaled a listed impairment; (4) if not, whether the impairment (or combination of impairments) prevented the claimant from performing past relevant work; and (5) if so, whether the impairment (or combination of impairments) prevented the claimant from performing any other jobs available in significant numbers in the national economy. 20 C.F.R. §§ 404.1520(a)-(g), 416.920(a)-(g).

2 syndrome bilaterally, obesity, and tobacco abuse. Id. After finding that Ms. Crick’s impairments did not meet or equal a Listing,2

the ALJ determined that Ms. Crick had the residual functional capacity (“RFC”) to perform work at the light exertional level, with additional limitations: (1) she cannot climb ladders, ropes, and scaffolds; (2) she can no more than frequently walk on

ramps and stairs; (3) she can no more than occasionally balance, stoop, kneel, crouch, and crawl; (4) she can no more than frequently reach, handle, and finger with the bilateral upper extremities; and (5) she should avoid concentrated exposure to dust, fumes, and inhalant irritants. (Tr. at 79-81).

The ALJ determined that Ms. Crick was unable to perform any past relevant work. (Tr. at 87). At Step Five, the ALJ relied on the testimony of a Vocational Expert (VE) to find that, considering Ms. Crick’s age, education, work experience,

and RFC, jobs existed in significant numbers in the national economy that she could perform, such as sitting room attendant, storage facility rental clerk, and mail clerk (non-postal). (Tr. at 87-89). Thus, the ALJ found that Ms. Crick was not disabled. Id.

III. Discussion: A. Standard of Review

2 20 C.F.R. Part 404, Subpart P, Appendix 1.

3 The Court’s function on review is to determine whether the Commissioner’s decision is supported by substantial evidence on the record as a whole and whether

it is based on legal error. Miller v. Colvin, 784 F.3d 472, 477 (8th Cir. 2015); see also 42 U.S.C. § 405(g). While “substantial evidence” is that which a reasonable mind might accept as adequate to support a conclusion, “substantial evidence on the

record as a whole” requires a court to engage in a more scrutinizing analysis: “[O]ur review is more than an examination of the record for the existence of substantial evidence in support of the Commissioner’s decision; we also take into account whatever in the record fairly detracts from that decision.” Reversal is not warranted, however, “merely because substantial evidence would have supported an opposite decision.”

Reed v. Barnhart, 399 F.3d 917, 920 (8th Cir. 2005) (citations omitted). In clarifying the “substantial evidence” standard applicable to review of administrative decisions, the Supreme Court has explained: “And whatever the meaning of ‘substantial’ in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence . . . ‘is more than a mere scintilla.’” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (quoting Consolidated Edison Co. v. NLRB, 59 S. Ct. 206, 217 (1938)). “It means—and means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Id.

4 It is not the task of this Court to review the evidence and make an independent decision. Neither is it to reverse the decision of the ALJ because there is evidence in

the record which contradicts his findings. The test is whether there is substantial evidence in the record as a whole which supports the decision of the ALJ. Miller, 784 F.3d at 477.

B. Factual Background Ms. Crick alleged that she had disabling back and neck pain. In August 2022, a lumbar MRI revealed scoliosis, bulging discs, and chronic disc degeneration. (Tr. at 84). A November 2023 cervical MRI showed degenerative disc disease with

foraminal stenosis, T7 compression fracture, edema, and mild upper thoracic levocurvature and mild lower thoracic dextrocurvature. (Tr. at 85, 964-966). Clinical exam showed some discomfort on flexion and extension in Ms. Crick’s back and

neck, but she had otherwise normal musculoskeletal exams, with generally normal gait, grossly normal strength and reflexes, and only mildly limited range of motion.3 (Tr. at 440-444, 555, 489, 600, 634-642, 710, 721, 934-949). At a September 2023 doctor’s appointment, Ms. Crick had no tenderness in her cervical, thoracic, or

lumbar spines. (Tr. at 933). Moreover, no doctor prescribed an assistive device. Ms.

3 Normal clinical findings may support an ALJ’s decision to deny benefits. Gowell v. Apfel, 242 F.3d 793, 796 (8th Cir. 2001).

5 Crick was referred to physical therapy, but there is no evidence indicating she pursued that. (Tr. at 83).

Ms.

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Crick v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crick-v-social-security-administration-ared-2025.