Hoffson v. O'Malley

CourtDistrict Court, E.D. Missouri
DecidedJune 18, 2024
Docket4:23-cv-00448
StatusUnknown

This text of Hoffson v. O'Malley (Hoffson v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hoffson v. O'Malley, (E.D. Mo. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

LARRY S. HOFFSON, ) ) Plaintiff, ) ) v. ) Case No. 4:23-CV-448 PLC ) MARTIN O’MALLEY1, ) Commissioner of Social Security. ) ) Defendant. )

MEMORANDUM AND ORDER Plaintiff Larry Hoffson seeks review of the decision of Defendant Social Security Commissioner Martin O’Malley, denying his applications for Disability Insurance Benefits (DIB) under Title II of the Social Security Act, and Supplemental Security Income (SSI) under Title XVI. Because the Court finds that substantial evidence supports the decision to deny benefits, the Court affirms the denial of Plaintiff’s applications. I. Background On July 29, 2019, Plaintiff filed applications for DIB and SSI, alleging he was disabled as of June 18, 2019 due to two degenerative discs, constant numbness and pain in his body and appendages, and lower back pain. (Tr. 134, 216-217, 232-238) The Social Security Administration (SSA) denied Plaintiff’s claims in November 2019, and he filed a timely request for a hearing before an administrative law judge (ALJ). (Tr. 154-155, 164-165) The SSA granted Plaintiff’s request for review and conducted a hearing in October 2020. (Tr. 106-133)

1 Martin O’Malley became the Commissioner of Social Security on December 20, 2023. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Martin O’Malley shall be substituted for Kilolo Kijakazi as the Defendant in this suit. See 42 U.S.C. § 405(g). Plaintiff, born January 25, 1969, testified during the first hearing before the ALJ that he lived in a house with his girlfriend and dogs. (Tr. 112-113) He completed several years of college, but did not obtain a degree. (Tr. 112) With respect to his abilities and activities, Plaintiff testified that he was able to feed his

dogs, but did not take them for walks. (Tr. 113) Plaintiff laundered his clothes in small loads (because heavy lifting was difficult), and his girlfriend folded the clothes. (Tr. 113-114) Plaintiff stated that he helped with the dishes “periodically throughout the day”, because the repetitive nature of the task as well as standing precluded completion in one session. (Tr. 114-115) Plaintiff testified that he was no longer able to type, because the numbness in his hands prevented him from feeling the keys. (Tr. 115) Plaintiff asserted that due to issues with his right knee and lower back, he was able to stand for only ten to fifteen minutes before needing to sit down or switch positions. (Tr. 117) He stated that he was able to shower and get dressed on his own “with some creativity.” (Tr. 118) A vocational expert testified at the October, 2020 hearing. (Tr. 122-132) He classified

Plaintiff’s past relevant work, and responded to a series of hypotheticals regarding job opportunities for an individual with Plaintiff’s qualifications and alleged limitations. (Id.) In a decision dated November 27, 2020, the ALJ applied the five-step evaluation set forth in 20 C.F.R. §§ 404.1520(a) and 416.920(a) and found that Plaintiff: (1) had not engaged in substantial gainful activity since June 18, 2019, the alleged onset date; and (2) had the severe impairments of degenerative disc disease and osteoarthritis in the cervical spine, status post-fusion; bilateral carpal tunnel syndrome; and degenerative joint disease in the right knee, that significantly limited his ability to perform basic work activities as required by SSR 85-28. (Tr. 17-18) At step three, the ALJ concluded that Plaintiff did not have an impairment or combination of impairments that met or medically equaled the severity of one of the listed impairments in 20 C.F.R. Part 404, Subpart P, Appendix 1. (Tr. 18) The ALJ found that, although “the claimant’s medically determinable impairments could reasonably be expected to cause the alleged symptoms”, “the claimant’s statements concerning the

intensity, persistence and limiting effects of these symptoms are not entirely consistent with the medical evidence and other evidence in the record[.]” (Tr. 19) As support, the ALJ recounted in detail the nature of Plaintiff’s medical history. (Tr. 19-21) He further evaluated the medical opinions and prior administrative medical findings in the record. (Tr. 20-22) After “careful consideration of the entire record”, the ALJ determined that Plaintiff had the RFC to perform light work, except that: he can lift up to 10 pounds occasionally and 10 pounds frequently2; can stand and/or walk about 6 hours out of an 8 hour workday, with normal breaks; can sit for about 6 hours out of an 8 hour workday, with normal breaks, except: the claimant can occasionally reach overhead on the right and frequently reach in all other directions; can frequently handle and finger bilaterally; cannot claim ladders, ropes, or scaffolds or crawl; can occasionally climb ramps and stairs, balance, stoop, kneel, and crouch; and should avoid concentrated exposure to excessive vibration.

(Tr. 19) Based on the vocational expert’s testimony, the ALJ found that Plaintiff maintained the ability to perform past relevant work as a customer service representative. (Tr. 22) The ALJ further found Plaintiff maintained the RFC to perform jobs that existed in significant numbers in the national economy, such as bench assembler, mail clerk, and office clerk. (Tr. 23-24) The ALJ therefore concluded that Plaintiff had not been under a disability, as defined in the Social Security Act, from June 18, 2019 through the date of the decision. (Tr. 24)

2 The Court recognizes the inconsistency in the ALJ’s lifting limitations. After the SSA Appeals Council denied Plaintiff’s request for review of the ALJ’s decision (Tr. 3-9), Plaintiff filed a Complaint for Judicial Review of Decision of the Commissioner of Social Security with this Court on May 28, 2021. (Case No. 4:21CV626 PLC, ECF No. 1). Plaintiff argued the ALJ erred by misclassifying Plaintiff’s past work, and by listing possible job

opportunities that were not supported by substantial evidence due to a lack of reliable basis for the vocational expert’s testimony. (Id., ECF No. 16). On January 19, 2022, Defendant filed a Motion to Reverse and Remand, stating “agency counsel determined that remand was necessary for further evaluation of Plaintiff’s claim.” (Id., ECF No. 23).3 In an opinion issued January 24, 2022, this Court granted the Commissioner’s unopposed motion to reverse and remand. (Id., ECF Nos. 25, 26). In an Order entered March 22, 2022, the SSA Appeals Council vacated the hearing decision, and remanded Plaintiff’s case to the ALJ for resolution of the following issues: • The finding in the decision that the claimant can return to past work as a customer service representative is not supported by substantial evidence because the record does not support that the claimant’s past work matches that occupation (Decision, pages 8-9). At the hearing, the vocational expert initially testified that one of the claimant’s past jobs was as a customer service representative (DOT #299.357-014). However, during cross-examination, the Administrative Law Judge notes that the job described by the claimant on page 5 of Exhibit 6E did not match the customer service representative occupation (Transcript of Oral Hearing, page 24).

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Bluebook (online)
Hoffson v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hoffson-v-omalley-moed-2024.