Force v. Kijakazi

CourtDistrict Court, E.D. Missouri
DecidedJune 5, 2023
Docket4:22-cv-01330
StatusUnknown

This text of Force v. Kijakazi (Force 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
Force v. Kijakazi, (E.D. Mo. 2023).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

JAMES D. FORCE, ) ) Plaintiff, ) ) v. ) No. 4: 22 CV 1330 JSD ) KILOLO KIJAKAZI, ) Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM This action is before the court for judicial review of the final decision of the defendant Commissioner of Social Security denying the application of plaintiff James D. Force for supplemental security income benefits under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381-1385. The parties have consented to the exercise of plenary authority by the undersigned United States Magistrate Judge pursuant to 28 U.S.C. § 636(c). For the reasons set forth below, the final decision of the Commissioner is affirmed.

I. BACKGROUND Plaintiff was born on May 7, 1960. He originally alleged a December 12, 2016, onset date, when he was 56 years old, but amended it to September 9, 2019 at his administrative hearing. He filed his application on September 19, 2019, alleging disability due to migraines, dizziness, hot flashes, and chronic back, knee, shoulder, and joint pain. (Tr. 324). His application was denied initially and on reconsideration, and he requested a hearing before an Administrative Law Judge (ALJ). (Tr. 194-203, 213-17). On November 23, 2021, following a hearing, an ALJ issued a decision finding that plaintiff was not disabled under the Act. (Tr. 12-23). The Appeals Council denied his request for review. (Tr. 1-6). Thus, the decision of the ALJ stands as the final decision of the Commissioner. II. ADMINISTRATIVE RECORD

The Court adopts Plaintiff’s Unopposed Statement of Facts (ECF No. 10-1), along with Defendant’s Response to Plaintiff’s Statement of Uncontroverted Facts (ECF No. 11-2). These facts, taken together, present a fair and accurate summary of the medical record and testimony at the evidentiary hearing. The Court will discuss specific facts in detail where relevant to this appeal. III. DECISION OF THE ALJ

On November 23, 2021, following a hearing, an ALJ found that Plaintiff was not disabled. At step one of the sequential evaluation, the ALJ found that Plaintiff had not engaged in substantial gainful activity since September 9, 2019, his amended alleged onset date. At step two, the ALJ found that Plaintiff had severe impairments of degenerative disc disease, right shoulder tendinitis, depressive disorder, anxiety disorder, impulse control disorder, and post-traumatic stress disorder. At step three, the ALJ found that Plaintiff did not have an impairment, or combination of impairments, that met or medically equaled the severity of a listing for presumptive disability. (Tr.

15). The ALJ found that Plaintiff had the residual functional capacity (RFC) to perform a range of “medium” work as defined under the regulations.1 He could frequently stoop, kneel, crouch,

1 See 20 C.F.R. § 416.967(c) (stating that medium work requires lifting no more than 50

pounds at a time with frequent lifting or carrying of objects weighing up to 25 pounds); - 2 - crawl, and climb ramps, stairs, ladders, ropes, and scaffolds, but needed to avoid workplace hazards. He could frequently reach overhead. He was limited to simple, routine tasks with minimal changes in duties and setting, occasional public interaction, and no fast-paced production work. (Tr. 17).

At step four, the ALJ found that Plaintiff could not perform his past relevant work (PRW) as a forklift operator and yard worker. Relying on vocational expert testimony, the ALJ concluded that plaintiff’s impairments would not preclude him from performing other work that exists in significant numbers in the national economy, including medium work as an assembler, packer, and warehouse worker. (Tr. 23, 80-81). Thus, the ALJ found Plaintiff was not disabled under the Act. (Tr. 23).

IV. STANDARD OF REVIEW The Court’s role on judicial review of the Commissioner’s final decision is to determine whether the Commissioner’s findings applied the relevant legal standards to facts that are

supported by substantial evidence in the record as a whole. Pate-Fires v. Astrue, 564 F.3d 935, 942 (8th Cir. 2009). “Substantial evidence is less than a preponderance, but is enough that a reasonable mind would find it adequate to support the Commissioner’s conclusion.” Id. In determining whether the evidence is substantial, the court considers evidence that both supports and detracts from the Commissioner’s decision. Id. As long as substantial evidence supports the

Social Security Ruling (SSR) 83-10, 1983 WL 31251, at *6 (clarifying that medium work generally requires standing or walking, off and on, for six hours and sitting intermittently during the remaining time of an eight-hour workday).

- 3 - decision, the Court may not reverse it merely because substantial evidence exists in the record that would support a contrary outcome or because the Court would have decided the case differently. See Krogmeier v. Barnhart, 294 F.3d 1019, 1022 (8th Cir. 2002). To be entitled to disability benefits, a claimant must prove he is unable to perform any

substantial gainful activity due to a medically determinable physical or mental impairment that would either result in death or which has lasted or could be expected to last for at least twelve continuous months. 42 U.S.C. § 423(a)(1)(D), (d)(1)(A); Pate-Fires, 564 F.3d at 942. A five-step regulatory framework is used to determine whether an individual is disabled. 20 C.F.R. § 404.1520(a)(4); see also Bowen v. Yuckert, 482 U.S. 137, 140-42 (1987) (describing five-step process). Steps one through three require the claimant to prove: (1) he is not currently engaged in substantial gainful activity; (2) he suffers from a severe impairment; and (3) his condition meets or equals a listed impairment. 20 C.F.R. § 404.1520(a)(4)(i)-(iii). If the claimant does not suffer from a listed impairment or its equivalent, the Commissioner’s analysis proceeds to Steps Four

and Five. Step four requires the Commissioner to consider whether the claimant retains the RFC to perform PRW. Id.; § 404.1520(a)(4)(iv). The claimant bears the burden of demonstrating he is no longer able to return to his PRW. Pate-Fires, 564 F.3d at 942. If the Commissioner determines the claimant cannot return to his PRW, the burden shifts to the Commissioner at step five to show the claimant retains the RFC to perform other work that exists in significant numbers in the national economy. Id.; 20 C.F.R. § 404.1520(a)(4)(v).

- 4 - V. DISCUSSION

Plaintiff argues the ALJ erred in finding he could perform medium work because, in formulating his RFC, the ALJ did not assess any limitations in his ability to stand and/or walk in violation of SSR 96-8p. He argues the ALJ erred in relying on outdated medical opinions and his own interpretation of the medical records.

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Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Cichocki v. Astrue
729 F.3d 172 (Second Circuit, 2013)
Pate-Fires v. Astrue
564 F.3d 935 (Eighth Circuit, 2009)
Casey v. Astrue
503 F.3d 687 (Eighth Circuit, 2007)
Cindy Ponder v. Carolyn W. Colvin
770 F.3d 1190 (Eighth Circuit, 2014)
Bryce Mabry v. Carolyn W. Colvin
815 F.3d 386 (Eighth Circuit, 2016)
Donald Fentress v. Carolyn W. Colvin
854 F.3d 1016 (Eighth Circuit, 2017)
Jason Bowers v. Kilolo Kijakazi
40 F.4th 872 (Eighth Circuit, 2022)

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Force v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/force-v-kijakazi-moed-2023.