Hager v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedMarch 18, 2025
Docket4:24-cv-00847
StatusUnknown

This text of Hager v. Social Security Administration (Hager 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
Hager v. Social Security Administration, (E.D. Ark. 2025).

Opinion

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

PAMELA JANE HAGER PLAINTIFF

V. No. 4:24-CV-00847-LPR-ERE

SOCIAL SECURITY ADMINISTRATION, COMMISSIONER DEFENDANT

RECOMMENDED DISPOSITION

This Recommended Disposition (“RD”) has been sent to United States District Judge Lee P. Rudofsky. You may file objections if you disagree with the findings and conclusions set out in the RD. Objections should be specific, include a factual or legal basis, and be filed within fourteen days. If you do not object, you risk waiving the right to appeal questions of fact, and Judge Rudofsky can adopt this RD without independently reviewing the record. I. Background On February 7, 2021, Ms. Pamela Hager filed an application for benefits due to knee injuries, arthritis, PTSD, anxiety, hypertension, asthma, fibromyalgia, and carpal tunnel syndrome. Tr. 11, 240. Ms. Hager’s claim was denied initially and upon reconsideration. An Administrative Law Judge (“ALJ”) held a telephonic hearing on July 17, 2023, where Ms. Hager appeared with her lawyer, and the ALJ heard testimony from Ms. Hager and a vocational expert (“VE”). Tr. 33-56. The ALJ issued a decision on November 24, 2023, finding that Ms. Hager was not disabled. Tr. 11-21. The Appeals Council denied Ms. Hager’s request for review, making the ALJ’s decision

the Commissioner’s final decision. Tr. 1-3. Ms. Hager, who was fifty-six years old at the time of the hearing, attended some college and has past relevant work experience as a patrolman and a check

cashier. Tr. 20, 53. II. The ALJ’s Decision1 The ALJ found that Ms. Hager had not engaged in substantial gainful activity since May 25, 2019, the alleged onset date. Tr. 13. The ALJ also concluded that Ms.

Hager has the following severe impairments: left knee tendon tear, status post-repair; left shoulder rotator cuff tear, status post-repair; cervical degenerative changes; hallux valgus of bilateral feet, status post right ankle avulsion fracture; bilateral

thumb degenerative changes; bilateral sensorineural hearing loss; asthma; coronary artery disease; congestive heart failure; venous insufficiency; and obesity. Tr. 14. However, the ALJ concluded that Ms. Hager did not have an impairment or

1 The ALJ followed the required sequential analysis 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; and (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). combination of impairments that met or equaled an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1. Tr. 15.

According to the ALJ, Ms. Hager had the residual functional capacity (“RFC”) to perform sedentary work, with the following limitations: (1) occasional climbing of ramps/stairs, balancing, stooping, kneeling, crouching, and crawling; (2)

no climbing of ladders, ropes, or scaffolds; (3) frequent use of the upper extremities to reach, handle, finger, and feel; (4) only occasional exposure to atmospheric conditions (such as fumes, noxious odors, dusts, mists, gases, and poor ventilation); and (5) no work in loud or very loud noise environments. Tr. 16.

In response to hypothetical questions incorporating the above limitations, the VE testified that a substantial number of potential jobs were available in the national economy that Ms. Hager could perform, such as her past relevant work as a check

cashier. Tr. 20. Accordingly, the ALJ found that Ms. Hager was not disabled. III. Discussion A. Standard of Review In this appeal, the Court must review the Commissioner’s decision for legal

error and determine whether the decision is supported by substantial evidence on the record as a whole. Brown v. Colvin, 825 F.3d 936, 939 (8th Cir. 2016) (citing Halverson v. Astrue, 600 F.3d 922, 929 (8th Cir. 2010)). “Substantial evidence” in

this context means “enough that a reasonable mind would find [the evidence] adequate to support the ALJ’s decision.” Slusser v. Astrue, 557 F.3d 923, 925 (8th Cir. 2009) (citation omitted). In making this determination, the Court must consider

not only evidence that supports the Commissioner’s decision, but also evidence that supports a contrary outcome. Milam v. Colvin, 794 F.3d 978, 983 (8th Cir. 2015). The Court will not reverse the Commissioner’s decision, however, “merely because

substantial evidence exists for the opposite decision.” Long v. Chater, 108 F.3d 185, 187 (8th Cir. 1997) (citation omitted). B. Ms. Hager’s Arguments for Reversal Ms. Hager contends that the Commissioner’s decision is not supported by

substantial evidence because: (1) the ALJ erred in determining that she could perform her past relevant work; (2) the RFC is unsupported by the record; and (3) the ALJ asked irrelevant financial questions. Doc. 9 at 14-23.

C. Analysis 1. The ALJ’s Findings on Past Relevant Work Ms. Hager asserts that the ALJ erred in determining that she could perform her past relevant work because the ALJ did not correctly identify her past work,

relied on unreliable VE testimony, and failed to resolve conflicts between the VE’s testimony and the DOT. Id. at 14-18. Based on Ms. Hager’s description of her employment history, the VE testified

that Ms. Hager’s past relevant work was as a check cashier (DOT 211.462-026). Tr. 53. While Ms. Hager may believe that she performed the job at a light work level, the VE testified that the job is generally performed at the sedentary level. The ALJ

asked the VE if the hypothetical person, with restrictions like those found in the RFC, could perform the job as it is generally performed in the economy, and the VE answered affirmatively. Tr. 54. Ultimately, the ALJ found that Ms. Hager could perform her past relevant work2 at the sedentary level, as that “job is generally

performed.” Tr. 20. See Evans v. Shalala, 21 F.3d 832, 834 (8th Cir. 1994) (“[E]ven though Evans cannot perform the actual demands of his particular past relevant work, if the ALJ finds he can carry out his job as performed generally within the

national economy, he is not disabled under the regulations.”). Ms. Hager also takes issue with the VE testifying that the SVP3 3 job can be learned in “up to 30 days.” Doc. 8 at 16, Tr. 53. Even assuming this statement is

erroneous, it is harmless, since Ms. Hager had no mental restrictions in her RFC. Notably, Ms. Hager’s issue with the VE’s description of her past relevant work and definition of SVP 3 were not raised during the hearing and Ms. Hager does

2 There is a typo in the ALJ’s finding, referencing “Check Casher” at one point, rather than Check Cashier.

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Related

Halverson v. Astrue
600 F.3d 922 (Eighth Circuit, 2010)
Slusser v. Astrue
557 F.3d 923 (Eighth Circuit, 2009)
Tracy Milam v. Carolyn W. Colvin
794 F.3d 978 (Eighth Circuit, 2015)
Timothy Brown v. Carolyn W. Colvin
825 F.3d 936 (Eighth Circuit, 2016)
Veronica Grindley v. Kilolo Kijakazi
9 F.4th 622 (Eighth Circuit, 2021)
Lisa Austin v. Kilolo Kijakazi
52 F.4th 723 (Eighth Circuit, 2022)

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Hager v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hager-v-social-security-administration-ared-2025.