Flores v. O'Malley

CourtDistrict Court, E.D. Missouri
DecidedSeptember 30, 2025
Docket2:24-cv-00046
StatusUnknown

This text of Flores v. O'Malley (Flores v. O'Malley) 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
Flores v. O'Malley, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI NORTHERN DIVISION

ANGEL M. FLORES, ) ) Plaintiff, ) ) vs. ) No. 2:24-cv-00046-MTS ) FRANK BISIGNANO, Commissioner of ) the Social Security Administration,1 ) ) Defendant. )

MEMORANDUM AND ORDER This matter is before the Court for review of the adverse decision of Defendant, the Commissioner of the Social Security Administration.2 On March 11, 2022, Angel Flores (“Plaintiff”) applied for Disability Insurance Benefits (“DIB”) under Title II of the Social Security Act (the “Act”), 42 U.S.C. §§ 401–434 and Supplemental Security Income (“SSI”) under Title XVI of the Act, 42 U.S.C. §§ 1381–1385. (Tr. 251–59). Plaintiff alleged disability due to epilepsy, severe anxiety, post-traumatic stress disorder (“PTSD”), schizophrenia, bipolar disorder, depression, personality disorder, migraines, gastroparesis, and fatty liver disease, with an alleged onset date of July 1, 2021. (Tr. 291). In July 2023, following a hearing, an Administrative Law Judge (“ALJ”) issued his decision finding that Plaintiff was not disabled under the Act. (Tr. 27). For the following reasons, the matter is reversed and remanded for further proceedings.

1 Frank Bisignano is now the Acting Commissioner of the Social Security Administration. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Dudek is substituted as the proper defendant.

2 Section 405(g) of Title 42 provides for judicial review of the SSA Commissioner’s “final decision.” After the ALJ concluded that Plaintiff was not disabled under the Act, (Tr. 27), the Appeals Council denied Plaintiff’s request for review (Tr. 1–5); thus, the ALJ’s decision stands as the Commissioner’s final decision. I. Standard of Review and Legal Framework To be eligible for disability benefits, Plaintiff must prove that she is disabled under the Act. Baker v. Sec’y of Health & Hum. Servs., 955 F.2d 552, 555 (8th Cir. 1992). The Act defines a 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), 1382c(a)(3)(A). A claimant will be found to have a disability “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 also unable to “engage in any other kind of substantial gainful work which exists in the national economy.” Id. at §§ 423(d)(2)(A), 1382c(a)(3)(B). The Social Security Administration has established a five-step sequential process for determining whether a claimant is disabled. 20 C.F.R. § 404.1520(a). Steps 1–3 require the claimant to prove: (1) she is not currently engaged in substantial gainful activity; (2) she suffers from a severe impairment; and (3) her disability meets or equals a listed impairment. Id. at

§ 404.1520(a)–(d). If the claimant does not suffer from a listed impairment or its equivalent, the analysis proceeds to Steps 4 and 5. Id. at § 416.920(e). At this point, the ALJ assesses the claimant’s residual functioning capacity (“RFC”), “which is the most a claimant can do despite h[is] limitations.” Moore v. Astrue, 572 F.3d 520, 523 (8th Cir. 2009); 20 C.F.R. § 404.1545. The United States Court of Appeals for the Eighth Circuit has noted that the ALJ must determine a claimant’s RFC based on all relevant, credible evidence in the record, including medical records, the observations of treating physicians and others, and the claimant’s own description of his symptoms and limitations. Goff v. Barnhart, 421 F.3d 785, 793 (8th Cir. 2005). At Step 4, the ALJ must determine whether the claimant can return to her past relevant work by comparing the RFC with the physical demands of the claimant’s past relevant work. 20 C.F.R. § 404.1520(f). If the ALJ finds at Step 4 that a claimant can return to past relevant work, the claimant is not disabled. Id. If the ALJ finds at Step 4 that a claimant cannot return to past relevant work, the burden shifts at Step 5 to the Administration to establish that the claimant maintains the RFC to perform a

significant number of jobs within the national economy. Id. at § 404.1520(g). The court’s role on judicial review is to decide whether the ALJ’s determination is supported by “substantial evidence” on the record as a whole. Wagner v. Astrue, 499 F.3d 842, 848 (8th Cir. 2007). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019). In determining whether the evidence is substantial, the Court considers evidence that both supports and detracts from the ALJ’s decision. Cox v. Astrue, 495 F.3d 614, 617 (8th Cir. 2007). Even if substantial evidence would have supported an opposite decision or the reviewing court might have reached a different conclusion had it been the finder of fact, the Court must affirm the Commissioner’s decision if the record contains substantial evidence to support it. See McNamara

v. Astrue, 590 F.3d 607, 610 (8th Cir. 2010) (explaining that if substantial evidence supports the Commissioner’s decision, the court “may not reverse, even if inconsistent conclusions may be drawn from the evidence, and even if [the court] may have reached a different outcome”); Locher v. Sullivan, 968 F.2d 725, 727 (8th Cir. 1992) (explaining a court may not reverse merely because substantial evidence would have supported an opposite decision). The Eighth Circuit has emphasized repeatedly that a court’s review of an ALJ’s disability determination is intended to be narrow and that courts should “defer heavily to the findings and conclusions of the Social Security Administration.” Hurd v. Astrue, 621 F.3d 734, 738 (8th Cir. 2010) (quoting Howard v. Massanari, 255 F.3d 577, 581 (8th Cir. 2001)). Despite this deferential stance, a district court’s review must be “more than an examination of the record for the existence of substantial evidence in support of the Commissioner’s decision,” Beckley v. Apfel, 152 F.3d 1056, 1059 (8th Cir. 1998), and not merely a “rubber stamp,” Cooper v.

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Related

Hurd v. Astrue
621 F.3d 734 (Eighth Circuit, 2010)
McCoy v. Astrue
648 F.3d 605 (Eighth Circuit, 2011)
Wildman v. Astrue
596 F.3d 959 (Eighth Circuit, 2010)
Wagner v. Astrue
499 F.3d 842 (Eighth Circuit, 2007)
Cox v. Astrue
495 F.3d 614 (Eighth Circuit, 2007)
McNamara v. Astrue
590 F.3d 607 (Eighth Circuit, 2010)
Moore v. Astrue
572 F.3d 520 (Eighth Circuit, 2009)
TAYLOR EX REL. MCKINNIES v. Barnhart
333 F. Supp. 2d 846 (E.D. Missouri, 2004)

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Bluebook (online)
Flores v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/flores-v-omalley-moed-2025.