Hall v. Social Security Administration Commissioner

CourtDistrict Court, W.D. Arkansas
DecidedAugust 1, 2022
Docket2:21-cv-02083
StatusUnknown

This text of Hall v. Social Security Administration Commissioner (Hall v. Social Security Administration Commissioner) is published on Counsel Stack Legal Research, covering District Court, W.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 Commissioner, (W.D. Ark. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF ARKANSAS FORT SMITH DIVISION

JOHN H. HALL, JR. . PLAINTIFF

V. Civil No. 2:21-cv-02083-PKH-MEF

KILOLO KIJAKAZI1, Acting Commissioner, Social Security Administration DEFENDANT

MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION Plaintiff, John Hall, Jr., brings this action under 42 U.S.C. § 405(g), seeking judicial review of a decision of the Commissioner of Social Security Administration (the “Commissioner”) denying his claim for a period of disability, disability insurance benefits (“DIB”), and supplemental security income (“SSI”) benefits under Titles II and XVI of the Social Security Act (hereinafter “the Act”), 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). In this judicial review, the Court must determine whether there is substantial evidence in the administrative record to support the Commissioner’s decision. See 42 U.S.C. § 405(g). I. Procedural Background Plaintiff filed his applications for DIB and SSI on February 2, 2017, and July 19, 2018, respectively, alleging disability since December 31, 20122, due to back, leg, and shoulder problems, as well as depression. (ECF No. 12, pp. 107, 119, 195-201, 210-215, 218-219, 233,

1 Kilolo Kijakazi became Acting Commissioner of the Social Security Administration on July 9, 2021. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Kilolo Kijakazi should be substituted as the defendant in this suit. No further action needs to be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g). 2 At the administrative hearing, Plaintiff amended his onset date from June 10, 2008, to December 31, 2012. (ECF No. 12, p. 46). 250-251). An administrative hearing was held on September 18, 2018. (Id. at 42-82). Plaintiff was present and represented by counsel. Born in 1968, Plaintiff was 44 years of age on his alleged onset date and possessed a high school education with some mechanical training. (ECF No. 12, p. 28). Although he had past

relevant work (“PRW”) experience as a street department laborer and dump truck driver, he performed no substantial gainful activity after his amended alleged onset date. (Id. at 17, 28, 234, 240-247). On June 12, 2019, the Administrative Law Judge (“ALJ”) entered an unfavorable decision, acknowledging ALJ Bill Jones’ April 8, 2014, decision denying Plaintiff’s May 31, 2012, DIB application.3 (ECF No. 12, p. 15). As such, he acknowledged that res judicata barred Plaintiff’s Title II application because both his amended onset date and date last insured, December 31, 2012, preceded the date of the prior ALJ’s decision. (Id. at 15, 17). The ALJ went on to consider Plaintiff’s Title XVI application, finding his spine disorder and other unspecified arthropathies to be severe, but assessing his hypertension, diabetes mellitus type II, and depression as non-severe

impairments, and ultimately concluding that the Plaintiff did not have an impairment or combination of impairments that met or medically equaled the severity of an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1. (Id. at 18-20). Further, he determined that the Plaintiff could perform light work with only occasional balancing, stooping, kneeling, crouching, crawling, and climbing. (Id. at 21). Because the Plaintiff cannot perform his PRW, which was considered medium level work, the ALJ relied on the testimony of a vocational expert (“VE”) who indicated

3 At the administrative hearing, the ALJ and Plaintiff’s counsel had a discussion regarding the effect res judicata would have on the Plaintiff’s present DIB application. (ECF No. 12, pp. 46-47). Neither the ALJ nor counsel completely understood why the present DIB application was allowed to proceed, given the prior decision, but counsel believed it had been allowed to proceed because the Agency found that it contained some new and material allegations. However, counsel admitted that the Plaintiff had a very slim chance of prevailing. (Id. at 46). that the Plaintiff could perform work as a power screwdriver operator, collator operator, and compression molding machine tender. (Id. at 29). The Appeals Council denied Plaintiff’s request for review on February 25, 2021. (ECF No. 12, pp. 6-11). Plaintiff subsequently filed this action on April 26, 2021. (ECF No. 2). Both

parties have filed appeal briefs (ECF Nos. 15, 16), and the matter is ready for Report and Recommendation. II. Applicable Law This Court’s role is to determine whether substantial evidence supports the Commissioner’s findings. Vossen v. Astrue, 612 F.3d 1011, 1015 (8th Cir. 2010). Substantial evidence is less than a preponderance but enough that a reasonable mind would find it adequate to support the Commissioner’s decision. Biestek v. Berryhill, 139 S.Ct. 1148, 1154 (2019). We must affirm the ALJ’s decision if the record contains substantial evidence to support it. Blackburn v. Colvin, 761 F.3d 853, 858 (8th Cir. 2014). If there is substantial evidence in the record that supports the Commissioner’s decision, the Court may not reverse it simply because substantial

evidence exists in the record that would have supported a contrary outcome, or because the Court would have decided the case differently. Miller v. Colvin, 784 F.3d 472, 477 (8th Cir. 2015). In other words, if after reviewing the record it is possible to draw two inconsistent positions from the evidence and one of those positions represents the findings of the ALJ, we must affirm the ALJ’s decision. Id. A claimant for Social Security disability benefits has the burden of proving his disability by establishing a physical or mental disability that has lasted at least one year and that prevents him from engaging in any substantial gainful activity. Pearsall v. Massanari, 274 F.3d 1211, 1217 (8th Cir. 2001); see also 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). The Act defines “physical or mental impairment” as “an impairment that results from anatomical, physiological, or psychological abnormalities which are demonstrable by medically acceptable clinical and laboratory diagnostic techniques.” 42 U.S.C. §§ 423(d)(3), 1382c(a)(3)(D). A Plaintiff must show that his disability, not simply his impairment, has lasted for at least twelve consecutive months.

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