Hall v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedJanuary 20, 2022
Docket3:20-cv-00353
StatusUnknown

This text of Hall v. Social Security Administration (Hall 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
Hall v. Social Security Administration, (E.D. Ark. 2022).

Opinion

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

TONYA HALL PLAINTIFF

V. NO. 3:20-CV-00353-JTK

KILOLO KIJAKAZI, COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION1 DEFENDANT

ORDER

I. Introduction:

Plaintiff, Tonya Hall (“Hall”), applied for disability benefits on September 20, 2018, alleging a disability onset date of June 24, 2017. (Tr. at 10). The claim was denied initially and upon reconsideration. Id. After conducting a hearing, the Administrative Law Judge (“ALJ”) denied Hall’s application on March 31, 2020. (Tr. at 22). The Appeals Council denied her request for review. (Tr. at 1). The ALJ=s decision now stands as the final decision of the Commissioner, and Hall has requested judicial review. For the reasons stated below, the Court2 affirms the decision of the Commissioner. II. The Commissioner=s Decision: The ALJ found that Hall had not engaged in substantial gainful activity since the alleged onset date of June 24, 2017.3 (Tr. at 12). The ALJ found, at Step Two, that Hall had the following

1 On July 9, 2021, Kilolo Kijakazi became the Acting Commissioner of the Social Security Administration and is substituted as the Defendant in this action. Fed. R. Civ. P. 25(d).

2 The parties have consented in writing to the jurisdiction of a United States Magistrate Judge.

3 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 severe impairments: degenerative disc disease, osteoarthritis, status-post knee surgery, carpal tunnel syndrome, and obesity. (Tr. at 13). After finding that Hall’s impairments did not meet or equal a listed impairment (Tr. at 13), the ALJ determined that Hall had the residual functional capacity (“RFC”) to perform work at the

light exertional level with exceptions: (1) she can only occasionally climb stairs, but never climb ladders; (2) she can only occasionally balance, stoop, kneel, crouch, and crawl; (3) she can frequently handle and finger bilaterally; (4) she must avoid hazards, such as unprotected heights and dangerous moving mechanical parts; (5) she can perform simple, routine, and repetitive tasks; (6) she can make simple work-related decisions and can concentrate, persist, and maintain pace with normal breaks; and (7) she requires interpersonal contact with simple, direct, and concrete supervision. (Tr. at 15). The ALJ found that Hall was unable to perform any of her past relevant work. (Tr. at 20). At Step Five, the ALJ relied upon Vocational Expert (“VE”) testimony to find that, based on Girard’s age, education, work experience and RFC, jobs existed in significant numbers in the

national economy that she could perform. (Tr. at 21). Therefore, the ALJ found that Hall 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.

performing any other jobs available in significant numbers in the national economy. 20 C.F.R. §§ 404.1520(a)-(g), 416.920(a)-(g).

2 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.”

Reed v. Barnhart, 399 F.3d 917, 920 (8th Cir. 2005) (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, 139 S. Ct. 1148, 1154 (2019) (quoting Consolidated Edison Co. v. NLRB, 59 S. Ct. 206, 217 (1938)). “It means—and means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Id. B. Hall=s Arguments on Appeal Hall contends that the evidence supporting the ALJ’s decision is less than substantial. She argues that the ALJ did not properly consider the opinion of Hall’s treating physician and that the RFC did not fully incorporate her limitations. For the following reasons, the Court finds that substantial evidence supports the ALJ=s decision. Hall’s complained of unrelenting back, neck, hip, and knee pain. However, objective imaging revealed no more than mild-to-moderate conditions. (Tr. at 16-18). After lumbar branch blocks, Hall said she was feeling better. (Tr. at 288-290). Her pain management doctor planned to

3 decrease her Hydrocodone at that point. Id. Hall’s regular nurse practitioner recommended weight loss and exercise, and said that Hall was not a surgical candidate for her back condition. (Tr. at 317-326). A physician’s recommendation to exercise suggests that a claimant has an increased functional capacity. See Moore v. Astrue, 572 F.3d 520, 524 (8th Cir. 2009). Another doctor

prescribed a home exercise program, and Hall said when she avoided certain activities, her pain improved. (Tr. at 396-398). She was treated conservatively with medications, branch blocks, and steroid injections, which provided some relief. Hall’s PCP, Dr. Sumner Cullom, urged Hall to stop smoking, which she did not do. (Tr. at 471-473). See Kisling v. Chater, 105 F.3d 1255, 1257 (8th Cir. 1997). Dr. Cullom said, on July 6, 2018, that he would not declare Hall disabled without a further workup. Id. On October 11, 2018, a note from Dr. Cullom said that Hall’s back pain was chronic but stable. (Tr.at 465-467). After carpal tunnel release surgery, Hall said the numbness and tingling in her hands was improved. (Tr. at 364-365). Improvement in condition supports an ALJ’s finding that a claimant is not disabled. See Lochner v. Sullivan, 968, F.2d 725, 728 (8th Cir. 1992). She agreed to perform

home exercise (Tr. at 365-368). After right knee surgery, she told her neurosurgeon that she was having no pain. (Tr. at 651-662). He told Hall to begin weight-bearing as tolerated. (Tr. at 682- 687). Hall could perform daily activities, like attending to personal care, driving, preparing meals, doing laundry, and shopping. (Tr. at 34-35. 237-241). Such daily activities undermine her claims of disability.

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Hall v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hall-v-social-security-administration-ared-2022.