Dugan v. Kijakazi

CourtDistrict Court, E.D. Missouri
DecidedSeptember 23, 2021
Docket1:20-cv-00105
StatusUnknown

This text of Dugan v. Kijakazi (Dugan v. Kijakazi) 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.

Bluebook
Dugan v. Kijakazi, (E.D. Mo. 2021).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEASTERN DIVISION

) AMY D. DUGAN, ) ) Plaintiff, ) ) v. ) Case No. 1:20-CV-00105-NCC ) KILOLO KIJAKAZI,1 ) Acting Commissioner of Social Security ) ) Defendant. )

MEMORANDUM AND ORDER This is an action under Title 42 U.S.C. § 405(g) for judicial review of the final decision of the Commissioner denying the application of Amy D. Dugan (“Plaintiff”) for Disability Insurance Benefits (“DIB”) under Title II of the Social Security Act, 42 U.S.C. § 401, et seq. Plaintiff has filed a brief in support of the Complaint (Doc. 19) and Defendant has filed a brief in support of the Answer (Doc. 20). The parties have consented to the jurisdiction of the undersigned United States Magistrate Judge pursuant to Title 28 U.S.C. § 636(c) (Doc. 9). I. PROCEDURAL HISTORY Plaintiff filed her application for DIB on January 13, 2017 (Tr. 200-01). Plaintiff was initially denied on November 28, 2017, and she filed a Request for Hearing before an Administrative Law Judge (“ALJ”) (Tr. 132-36, 139-40). After a hearing, by decision dated June 7, 2019, the ALJ found Plaintiff not disabled (Tr. 18-35). On April 22, 2020, the Appeals

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 shall be substituted for former Commissioner 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). Council denied Plaintiff’s request for review (Tr. 1-5). As such, the ALJ’s decision stands as the final decision of the Commissioner. II. DECISION OF THE ALJ The ALJ determined that Plaintiff meets the insured status requirements of the Social Security Act through December 31, 2022, and that Plaintiff has not engaged in substantial

gainful activity since January 1, 2017, the alleged onset date (Tr. 23). The ALJ found Plaintiff has the severe impairments of rheumatoid arthritis, fibromyalgia, mild neurocognitive impairment due to rheumatoid arthritis, status post left hip arthroplasty, and atrioventricular block, status post-pacemaker placement, but that no impairment or combination of impairments met or medically equaled the severity of one of the listed impairments in 20 C.F.R. Part 404, Subpart P, Appendix 1 (Tr. 23-34). After considering the entire record, the ALJ determined Plaintiff has the residual functional capacity (“RFC”) to perform sedentary work with the following limitations (Tr. 24). Plaintiff cannot climb ladders, ropes, or scaffolds (Id.). Plaintiff can occasionally climb ramps and stairs and she can engage in occasional balancing and stooping

(Id.). Plaintiff cannot engage in kneeling, crouching or crawling and can occasionally perform overhead reaching, pushing, or pulling bilaterally (Id.). Plaintiff can frequently perform handling and fingering activities (Id.). Plaintiff cannot work at unprotected heights, around moving mechanical parts or other such hazards (Id.). Plaintiff is limited to performing simple routine tasks and can work at a consistent pace throughout the workday, but not at a production rate pace where each task must be completed within a strict time deadline (Tr. 24-25). Plaintiff is limited to work that requires only occasional changes in the work setting (Tr. 25). The ALJ found Plaintiff unable to perform any past relevant work but that there are jobs that exist in significant numbers in the national economy that Plaintiff can perform including hand assembler, machine tender, and table worker (Tr. 27-29). Thus, the ALJ concluded that Plaintiff has not been under a disability from January 1, 2017, through the date of the decision (Tr. 27). III. LEGAL STANDARD Under the Social Security Act, the Commissioner has established a five-step process for determining whether a person is disabled. 20 C.F.R. §§ 416.920, 404.1529. “If a claimant fails

to meet the criteria at any step in the evaluation of disability, the process ends and the claimant is determined to be not disabled.” Goff v. Barnhart, 421 F.3d 785, 790 (8th Cir. 2005) (quoting Eichelberger v. Barnhart, 390 F.3d 584, 590-91 (8th Cir. 2004)). In this sequential analysis, the claimant first cannot be engaged in “substantial gainful activity” to qualify for disability benefits. 20 C.F.R. §§ 416.920(b), 404.1520(b). Second, the claimant must have a severe impairment. 20 C.F.R. §§ 416.920(c), 404.1520(c). The Social Security Act defines “severe impairment” as “any impairment or combination of impairments which significantly limits [claimant’s] physical or mental ability to do basic work activities. . . .” Id. “‘The sequential evaluation process may be terminated at step two only when the claimant’s impairment or combination of impairments

would have no more than a minimal impact on [his or] her ability to work.’” Page v. Astrue, 484 F.3d 1040, 1043 (8th Cir. 2007) (quoting Caviness v. Massanari, 250 F.3d 603, 605 (8th Cir. 2001), citing Nguyen v. Chater, 75 F.3d 429, 430-31 (8th Cir. 1996)). Third, the ALJ must determine whether the claimant has an impairment which meets or equals one of the impairments listed in the Regulations. 20 C.F.R. §§ 416.920(d), 404.1520(d). If the claimant has one of, or the medical equivalent of, these impairments, then the claimant is per se disabled without consideration of the claimant’s age, education, or work history. Id. Fourth, the impairment must prevent the claimant from doing past relevant work. 20 C.F.R. §§ 416.920(f), 404.1520(f). The burden rests with the claimant at this fourth step to establish his or her RFC. Steed v. Astrue, 524 F.3d 872, 874 n.3 (8th Cir. 2008) (“Through step four of this analysis, the claimant has the burden of showing that she is disabled.”). The ALJ will review a claimant’s RFC and the physical and mental demands of the work the claimant has done in the past. 20 C.F.R. § 404.1520(f). Fifth, the severe impairment must prevent the claimant from doing any other work. 20

C.F.R. §§ 416.920(g), 404.1520(g). At this fifth step of the sequential analysis, the Commissioner has the burden of production to show evidence of other jobs in the national economy that can be performed by a person with the claimant’s RFC. Steed, 524 F.3d at 874 n.3. If the claimant meets these standards, the ALJ will find the claimant to be disabled.

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Bluebook (online)
Dugan v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dugan-v-kijakazi-moed-2021.