Hackworth v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedSeptember 11, 2024
Docket3:23-cv-00204
StatusUnknown

This text of Hackworth v. Social Security Administration (Hackworth 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
Hackworth v. Social Security Administration, (E.D. Ark. 2024).

Opinion

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

JAMES OWEN HACKWORTH PLAINTIFF

V. Case No. 3:23-CV-00204-BBM

MARTIN O’MALLEY, Commissioner, Social Security Administration1 DEFENDANT

ORDER2

I. INTRODUCTION

On November 17, 2020, Plaintiff James Owen Hackworth (“Hackworth”) filed a Title XVI application with the Social Security Administration (“SSA”) for supplemental security income.3 (Tr. at 11). In the application, Hackworth alleged that he became disabled on January 1, 2019. Id. The application was denied at the initial administrative level and upon reconsideration. Id. After conducting a hearing, an Administrative Law Judge (“ALJ”) issued a written decision finding that Hackworth was not disabled. (Tr. at 11–20). The Appeals Council denied Hackworth’s request for review of the ALJ’s decision on October 11, 2023. (Tr. at 1–6). The ALJ’s decision now stands as the final decision of the Commissioner, and Hackworth has requested judicial review.

1 On December 20, 2023, Martin J. O’Malley was sworn in as Commissioner of the Social Security Administration (“the Commissioner”). Pursuant to Federal Rule of Civil Procedure 25(d), Commissioner O’Malley is automatically substituted as the Defendant.

2 The parties consented in writing to the jurisdiction of a United States Magistrate Judge. (Doc. 5).

3 Hackworth was 19 years old on the application date. For the reasons stated below, the Court affirms the decision of the Commissioner. II. THE COMMISSIONER’S DECISION

The ALJ found that Hackworth had not engaged in substantial gainful activity since the application date of November 17, 2020.4 (Tr. at 13, 19). At Step Two, the ALJ determined that Hackworth has the following severe impairments: autism, separation anxiety disorder, borderline intellectual functioning, and learning disorder. (Tr. at 13). At Step Three, the ALJ determined that Hackworth’s impairments did not meet or equal a Listing.5 (Tr. at 13–16). Before proceeding to Step Four, the ALJ determined that

Hackworth had the residual functional capacity (“RFC”) to perform work at all exertional levels, but with additional mental restrictions: (1) he is capable of understanding, remembering, and carrying out simple but not complex instructions; (2) he can have no interaction with the general public; and (3) he can have no more than occasional changes to the workplace setting. (Tr. at 16).

At Step Four, the ALJ determined that Hackworth had no past relevant work. (Tr. at 19–20). At Step Five, the ALJ relied upon testimony from a Vocational Expert to determine that, based on Hackworth’s age, education, work experience, and RFC, he was

4 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). For Title XVI claims, the relevant time-period begins on the application date. (Tr. at 11).

5 20 C.F.R. §§ 416.920(d), 416.925, and 416.926. capable of performing work in the national economy. Id. Therefore, the ALJ concluded that Hackworth 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: [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.

Haley v. Massanari, 258 F.3d 742, 747 (8th Cir. 2001) (internal quotations and 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, 587 U.S. 97, 103 (2019) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 217 (1938)). “It means—and means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Id. B. Brief Summary of Hackworth’s Psychiatric Evaluations and Treatment

In February and March of 2018, Hackworth saw Psychological Examiner David Shade (“Shade”) on a referral from his primary care physician, Dr. Dennis Blake. (Tr. at 455). Hackworth was referred to psychiatry to consider an autism spectrum disorder; Hackworth was already being treated for obsessive-compulsive disorder and separation anxiety disorder. Id. Shade’s notes indicate that Hackworth had been prescribed Lexapro, to be taken daily. Id. After completion of testing, Shade diagnosed Hackworth with separation anxiety disorder, by history; autism spectrum disorder requiring substantial

support; and specific learning disability in reading, math, and written expression.6 (Tr. at 464). On December 18, 2020, Hackworth visited Nurse Chris Stone for pharmacologic management. (Tr. at 343). As of that appointment date, Hackworth was prescribed fluvoxamine (daily for mood), trazadone (for sleep), and propranolol (as needed for

anxiety). Id. At the December 18, 2020 appointment, Hackworth agreed to continue the above-listed medications, and Nurse Stone increased his dosage of fluvoxamine. (Tr. at 344, 346). On February 9, 2021, Stone and Hackworth’s counselor, Keri Henson, noted that “[p]rogress has been made.” (Tr. at 354–355). On April 8, 2021, Hackworth saw psychiatric consultative examiner, Anita Wells,

Ph.D (“Dr. Wells”), who conducted a mental diagnostic exam. (Tr. at 324–334). Dr. Wells thoroughly interviewed Hackworth for social, educational, and treatment history and found

6 Hackworth was also diagnosed with a learning disability in school and received accommodations based thereupon, which helped him. (Tr. at 396–474). few deficits in mental function. Id. She noted he had a happy mood, pleasant affect, adequate speech, logical thought process, and no hallucinations or suicidal ideations. (Tr.

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