Howell v. King

CourtDistrict Court, E.D. Missouri
DecidedJanuary 31, 2025
Docket4:23-cv-01265
StatusUnknown

This text of Howell v. King (Howell v. King) 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
Howell v. King, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

MICHAEL H. H., JR., ) ) Plaintiff, ) ) ) v. ) Case No. 4:23-cv-01265-JSD ) MICHELLE KING, ) Acting Commissioner of Social Security,1 ) ) ) Defendant. )

MEMORANDUM OPINION

This is an action under 42 U.S.C. §§ 405(g) for judicial review of the final decision of Defendant Michelle King, Acting Commissioner of Social Security (the “Commissioner”) denying the application of Plaintiff Michael H. H., Jr., (“Plaintiff”) for Disability Insurance Benefits (“DIB”) under Title II of the Social Security Act, 42 U.S.C. §§ 401 et seq. The parties consented to the jurisdiction of the undersigned magistrate judge pursuant to 28 U.S.C. § 636(c). (ECF No. 6). This Court affirms the Commissioner’s denial of Plaintiff’s application because the decision denying benefits was supported by substantial evidence. I. BACKGROUND On June 4, 2021, Plaintiff applied for DIB, alleging that he had been unable to work since March 1, 2021, due to a spinal facture with nerve damage, left shoulder strain, problems with the left knee, high blood pressure, osteoarthritis, patellar chondromalacia, sleep apnea, liver

1 Michelle King became the Acting Commissioner of Social Security in January 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Michelle King should be substituted, therefore, for Martin J. O’Malley as the defendant in this suit. No further action need 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). problems, and anxiety. (Tr. 14, 246). His application was initially denied. (Tr. 124). On June 28, 2022, Plaintiff filed a Request for Hearing by Administrative Law Judge (ALJ) (Tr. 127). After a hearing, the ALJ issued an unfavorable decision on January 26, 2023. (Tr. 48-67). Plaintiff filed a Request for Review of Hearing Decision with the Social Security Administration’s Appeals

Council on February 10, 2023, but the Appeals Council declined to review the case on August 8, 2023. (Tr. 1). Plaintiff has exhausted all administrative remedies, and the decision of the ALJ stands as the final decision of the Commissioner of the Social Security Administration.2 At his hearing before the ALJ on November 22, 2022, Plaintiff testified to the following: He is able to do basic self-care acts like using the toilet, showering, dressing himself, and feeding himself. (Tr. 36). He receives help from family with cleaning and yardwork. (Tr. 36-37). His most severe issues were pain in his back, legs, and knee. (Tr. 40). He has had back pain since he broke it and it radiates throughout his body. (Tr. 42). At his best, his back pain is a three out of ten but it can go up to an eight or nine. (Tr. 43). He’s had multiple knee injuries and surgeries throughout his life and needs his left knee replaced. (Tr. 43). All movements other than standing

make his knee pain worse. (Tr. 44). He has shoulder issues and cannot lift his left arm higher than just below shoulder level. (Tr. 45). He has been diagnosed with cirrhosis and it causes constant dull throbbing abdominal pain. (Tr. 45-46). He can only walk for 20-30 minutes at a time. (Tr. 49). He sleeps during the day because he has sleep apnea. (Tr. 49). The Court accepts the facts as set forth in the parties’ respective statements of fact and responses. The Court will cite to specific portions of the transcript as needed to address the parties’ arguments.

2 On October 2, 2019, an ALJ issued an unfavorable decision finding that Plaintiff is limited to sedentary work. (Tr. 63) The Appeals Council remanded the decision because an ALJ issued another unfavorable decision on February 17, 2021, finding that Plaintiff is limited to light work. (Tr. 81) Plaintiff did not appeal but filed a new application, at issue herein. III. STANDARD FOR DETERMINING DISABILITY UNDER THE ACT To be eligible for benefits under the Social Security Act, a claimant must prove he or she is disabled. Pearsall v. Massanari, 274 F.3d 1211, 1217 (8th Cir. 2001); Baker v. Sec’y of Health & Hum. Servs., 955 F.2d 552, 555 (8th Cir. 1992). Under the Social Security Act, a person is

disabled if she is unable “to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. §§ 423(d)(1)(A). Accord Hurd v. Astrue, 621 F.3d 734, 738 (8th Cir. 2010). The impairment must be “of such severity that he [or she] is not only unable to do his [or her] previous work but cannot, considering his [or her] age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy, regardless of whether such work exists in the immediate area in which he [or she] lives, or whether a specific job vacancy exists for him [or her], or whether he [or she] would be hired if he [or she] applied for work.” 42 U.S.C. §§ 423(d)(2)(A).

To determine whether a claimant is disabled, the Commissioner engages in a five-step evaluation process. 20 C.F.R. §§ 404.1520(a); see also McCoy v. Astrue, 648 F.3d 605, 611 (8th Cir. 2011) (discussing the five-step process). At Step One, the Commissioner determines whether the claimant is currently engaging in “substantial gainful activity”; if so, then the claimant is not disabled. 20 C.F.R. §§ 404.1520(a)(4)(i); McCoy, 648 F.3d at 611. At Step Two, the Commissioner determines whether the claimant has “a severe medically determinable physical or mental impairment that meets the [twelve-month duration requirement in § 404.1509], or a combination of impairments that is severe and meets the duration requirement”; if the claimant does not have a severe impairment, the claimant is not disabled. 20 C.F.R. §§ 404.1520(a)(4)(ii); McCoy, 648 F.3d at 611. To be severe, an impairment must “significantly limit[] [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c). At Step Three, the Commissioner evaluates whether the claimant’s impairment meets or equals one of the impairments listed in 20 C.F.R. Part 404, Subpart P, Appendix 1 (the

“listings”). 20 C.F.R. §§

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Howell v. King, Counsel Stack Legal Research, https://law.counselstack.com/opinion/howell-v-king-moed-2025.