Hill v. Social Security Administration

District Court, E.D. Arkansas·Decided April 2, 2025·No. 4:24-cv-00443·Unknown

Opinion

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

CASSANDRA HILL PLAINTIFF

V. Case No. 4:24-CV-00443-BBM

LELAND DUDEK, Acting Commissioner, Social Security Administration1 DEFENDANT

ORDER

I. INTRODUCTION

On December 9, 2020, Plaintiff Cassandra Hill (“Hill”) filed a Title II application with the Social Security Administration for disability and disability insurance benefits. (Tr. at 54). On the same day, she filed a Title XVI application for supplemental security income. Id. In both applications, Hill alleged that she became disabled on February 1, 2016. Id. The applications were denied initially and upon reconsideration. Id. After conducting a hearing, an Administrative Law Judge (“ALJ”) issued a written decision on April 21, 2023, finding that Hill was not disabled. (Tr. at 54-69). The Appeals Council denied Hill’s request for review of the ALJ’s decision on March 15, 2024. (Tr. at 38-44). The ALJ’s decision now stands as the final decision of the Commissioner, and Hill has requested judicial review. For the reasons stated below, the Court affirms the decision of the Commissioner.

1 As of the date of this Order, Leland Dudek serves as Acting Commissioner of the Social Security Administration. Pursuant to Federal Rule of Civil Procedure 25(d), Acting Commissioner Dudek is automatically substituted as the Defendant. II. THE COMMISSIONER’S DECISION2

Hill previously filed Title II and Title XVI applications for disability insurance benefits and supplemental security income, which were denied on April 11, 2019. (Tr. at 54–55, 95–104). Hill did not move to reopen those applications, and the ALJ in this case declined to reopen those claims. (Tr. at 54). Accordingly, the first day of the relevant time- period for the determination of eligibility for benefits in this case is April 12, 2019, not the alleged February 1, 2016 onset date of disability.3 Id. Hill had not engaged in substantial gainful activity since April 12, 2019. (Tr. at 55–

58, 68). The ALJ found that Hill met the insured status requirements of the Social Security Act through September 30, 2019. (Tr. at 57). At Step Two, the ALJ determined that Hill has the following severe impairments: “depression, anxiety, and post-traumatic stress disorder (PTSD).” (Tr. at 57). At Step Three, the ALJ found that Hill’s impairments did not meet or equal a Listing.4 (Tr. at 57–

58). Before proceeding to Step Four, the ALJ stated that Hill had the residual functional capacity (“RFC”) to perform work at the light exertional level, with additional mental restrictions: (1) she is able to perform simple, routine, and repetitive tasks involving 1-to-

2 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).

3 Hill was 36 years old on the alleged onset date of disability. (Tr. at 68).

4 20 C.F.R. Part 404, Subpt. P, Appendix 1 (20 C.F.R. §§ 404.1520(d), 404.1525, 404.1526, 416.920(d), 416.925, and 416.926). 2 steps with the ability to make simple, work-related decisions; (2) she can have no more than occasional interaction with co-workers and supervisors and none with the public; (3) she has the ability to adapt to simple or routine changes where such changes are few and

infrequent; (4) she can perform work at a normal pace without high-rate production quotas; and (5) she should not be an integral part of a team. (Tr. at 60). At Step Four, the ALJ determined that Hill is unable to perform any past relevant work. (Tr. at 67–69). At Step Five, the ALJ relied upon testimony from a Vocational Expert (“VE”) to determine that, based on Hill’s age, education, work experience, and RFC, she

was capable of performing work in the national economy. (Tr. at 68–69). Therefore, the ALJ concluded that Hill was not disabled. (Tr. at 69). 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. Hill’s Arguments on Appeal Hill contends that the ALJ erred as a matter of law by: (1) failing to account for Hill’s “marked” limitations in her ability to interact with others in the RFC, (Doc. 8 at 9– 13); and (2) failing to build an accurate and logical bridge between the evidence to the final RFC, id. at 13–15. The Court will address each of these arguments below.

1. The RFC was supported by substantial evidence.

Hill argues that the ALJ limiting her to “occasional interaction with co-workers and supervisors” was not sufficient to account for her “marked” limitation in her ability to interact with others.5 (Doc. 8 at 10). Specifically, Hill asserts that a limitation of “occasional interaction” is more consistent with a “finding of moderate social limitations,” not marked limitations. Id. (emphasis in original). To support this contention, Hill cites a number of in-circuit district-court opinions. Id. at 10–11 (collecting cases). For the reasons

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