Daniel v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedMay 12, 2023
Docket4:22-cv-00299
StatusUnknown

This text of Daniel v. Social Security Administration (Daniel 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
Daniel v. Social Security Administration, (E.D. Ark. 2023).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

LORI J. DANIEL PLAINTIFF

V. No. 4:22-CV-299-BRW-JTR

KILOLO KIJAKAZI, Acting Commissioner, Social Security Administration DEFENDANT

RECOMMENDED DISPOSITION This Recommended Disposition (“Recommendation”) has been sent to United States District Judge Billy Roy Wilson. 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, Judge Wilson 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 On June 1, 2020, Plaintiff Lori J. Daniel (“Daniel”) filed a Title II application for a period of disability and disability insurance benefits. (Tr. at 11). In the application, she alleged disability beginning on July 1, 2014. Id. She later amended her onset date to no earlier than December 1, 2016, and no later than December 31, 2018. Id.

Subsequent to a prior application, an Administrative Law Judge (“ALJ”) concluded, in a written decision dated November 30, 2017, that Daniel was not disabled. Id. Res judicata bars the reopening of that prior application, so the

beginning of the adjudicated period for the instant application is December 1, 2017, the day after the first ALJ’s decision. Id.; see 20 C.F.R. § 404.957. Additionally, the date last insured for Daniel is December 31, 2019; in order to prevail, she must show disability prior to that date.1 (Tr. at 12–14).

Daniel’s instant application was denied at the initial and reconsideration levels of review. (Tr. at 107–12). In a written decision dated June 9, 2021, an ALJ denied Daniel’s application. (Tr. at 11–23). The Appeals Council denied Daniel’s request

for review on February 2, 2022. (Tr. at 1–5). The ALJ’s decision now stands as the final decision of the Commissioner, and Daniel has requested judicial review. For the reasons stated below, the Court concludes that the Commissioner’s decision should be affirmed.

II. The Commissioner’s Decision The ALJ found that Daniel did not engage in substantial gainful activity during the period from her amended alleged onset date of December 1, 2017, through

1 Pyland v Apfel, 149 F.3d 873, 876 (8th Cir. 1998) (citing 42 U.S.C. §§ 416(i), 423(c)). her date last insured of December 31, 2019.2 (Tr. at 14). At Step Two, the ALJ determined that Daniel has the following severe impairments: degenerative disc

disease and dysfunction of a joint. Id. At Step Three, the ALJ determined that Daniel’s impairment did not meet or equal a listed impairment.3 Id. Before proceeding to Step Four, the ALJ determined

that Daniel had the residual functional capacity (“RFC”) to perform work at the light exertional level, although she could no more than occasionally stoop and crouch. (Tr. at 16). At Step Four, the ALJ utilized testimony from a Vocational Expert (“VE”) to

determine that Daniel was capable of performing past relevant work as a stock clerk.4 (Tr. at 21). Further relying upon VE testimony, the ALJ found, based on Daniel’s age, education, work experience and RFC, that there are jobs in the national

economy that Daniel can perform, including positions such as powered screwdriver

2 The ALJ followed 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).

3 20 C.F.R. Part 404, Subpt. P, Appendix 1 (20 C.F.R. §§ 404.1520(d), 404.1525, and 404.1526).

4 The VE testified that the stock clerk position was heavy exertional work, as generally performed, but light exertional work as actually performed at Acosta and medium exertional work as actually performed at Hallmark and Major Brand. (Tr. at 21, 57). Daniel’s RFC provided for light exertional work. (Tr. at 16). operator, merchandise marker, and small product assembler. (Tr. at 22–23, 58). Therefore, the ALJ concluded that Daniel was not disabled. Id.

III. Discussion A. Standard of Review 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: Our 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, 305 U.S. 197, 229 (1938)). “It means—and means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Id.

B. Daniel’s Arguments on Appeal Daniel contends that the evidence supporting the ALJ’s decision to deny benefits is less than substantial. She argues that: (1) the ALJ did not fully develop

the record; (2) the ALJ did not properly evaluate Daniel’s subjective complaints; and (3) the RFC did not incorporate all of Daniel’s credible limitations. Daniel focuses her arguments on her back injury.5 Pain management records document lumbar spondylosis, sacroiliac disorder, lumbar degenerative disc disease,

and trochanteric bursitis of the left hip. (Tr. at 17, 315–19).

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Daniel v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/daniel-v-social-security-administration-ared-2023.