Howlett v. O'Malley

CourtDistrict Court, E.D. Missouri
DecidedSeptember 13, 2024
Docket2:23-cv-00014
StatusUnknown

This text of Howlett v. O'Malley (Howlett 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
Howlett v. O'Malley, (E.D. Mo. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI NORTHERN DIVISION

CYNTHIA R. HOWLETT, ) ) Plaintiff, ) ) v. ) Case No. 2:23CV14 JAR ) MARTIN J. O’MALLEY,1 ) Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM AND ORDER This is an action under 42 U.S.C. § 405(g) for judicial review of the Commissioner of Social Security's final decision denying Plaintiff Cynthia R. Howlett’s application for disability and disability insurance benefits (“DIB”) under Title II, 42 U.S.C. §§ 401, et seq. For the reasons discussed below, the decision of the Commissioner will be affirmed. Background On March 11, 2021, Plaintiff protectively filed an application for a period of disability and DIB with an alleged onset date of February 28, 2021. Plaintiff claimed disability due to degenerative joint disease, high blood pressure, and depression. After Plaintiff’s application was initially denied, Plaintiff requested a hearing before an Administrative Law Judge (“ALJ”). A video hearing was held on July 28, 2022. Plaintiff was represented by counsel at the hearing, and the ALJ heard evidence from both Plaintiff and an impartial vocational expert (“VE”). After considering the testimony and record evidence, the ALJ issued an unfavorable decision on August

1 Martin J. 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 J. O’Malley should be substituted, therefore, for Kilolo Kijakazi 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). 10, 2022. The Appeals Council denied Plaintiff’s request for review of this decision. Thus, the decision of the ALJ stands as the final decision of the Commissioner. See Sims v. Apfel, 560 U.S. 103, 107 (2000). Facts

The Court adopts Plaintiff’s Statement of Material Facts [ECF No. 18-1] and Defendant’s Response [ECF No. 21-1]. These statements provide a fair and accurate description of the relevant record before the Court. Additional specific facts from the record, including Plaintiff’s testimony and medical records, will be discussed as necessary to address the parties’ arguments. Legal Standard To be eligible for benefits under the Social Security Act, Plaintiff must prove that she is disabled. Pearsall v. Massanari, 274 F.3d 1211, 1217 (8th Cir. 2001); Baker v. Secretary of Health & Human Servs., 955 F.2d 552, 555 (8th Cir. 1992). A disability is defined as the inability “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 twelve months.” 42 U.S.C. § 1382c(a)(3)(A). A claimant has a disability “only if [her] physical or mental impairment or impairments are of such severity that [she] is not only unable to do [her] previous work but cannot, considering [her] age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy[.]” Id. at § 1382c(a)(3)(B). The Commissioner follows a five-step sequential process when evaluating whether the claimant has a disability. 20 C.F.R. § 416.920(a)(1). At Step One, the Commissioner considers the claimant’s work activity. If the claimant is engaged in substantial gainful activity, the claimant is not disabled. 20 C.F.R. § 416.920(a)(4)(i). At Step Two, if the claimant is not engaged in substantial gainful activity, the Commissioner looks to see whether the claimant has a severe impairment “which significantly limits claimant’s physical or mental ability to do basic work activities.” Hurd v. Astrue, 621 F.3d 734, 738 (8th Cir. 2010); see also, 20 C.F.R. § 416.920(a)(4)(ii). “An impairment is not severe if it amounts only to a slight abnormality that

would not significantly limit the claimant’s physical or mental ability to do basic work activities.” Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007); see also, 20 C.F.R. §§ 416.920(c), 416.920a(d). At Step Three, if the claimant has a severe impairment, the Commissioner considers the impairment’s medical severity. If the impairment meets or equals one of the presumptively disabling impairments listed in the regulations, the claimant is considered disabled, regardless of age, education, and work experience. 20 C.F.R. §§ 416.920(a)(4)(iii), (d). At Step Four, if the claimant’s impairment is severe, but it does not meet or equal one of the presumptively disabling impairments, the Commissioner assesses whether the claimant retains the “residual functional capacity” (“RFC”) to perform his or her past relevant work. 20 C.F.R. §§ 416.920(a)(4)(iv), 416.945(a)(5)(i). An RFC is “defined as the most a claimant can still do despite his or her physical

or mental limitations.” Martise v. Astrue, 641 F.3d 909, 923 (8th Cir. 2011); see also, 20 C.F.R. § 416.945(a)(1). While an RFC must be based “on all relevant evidence, including the medical records, observations of treating physicians and others, and an individual’s own description of [her] limitations,” an RFC is nonetheless an “administrative assessment”—not a medical assessment—and therefore “it is the responsibility of the ALJ, not a physician, to determine a claimant’s RFC.” Boyd v. Colvin, 831 F.3d 1015, 1020 (8th Cir. 2016). Thus, “there is no requirement that an RFC finding be supported by a specific medical opinion.” Hensley v. Colvin, 829 F.3d 926, 932 (8th Cir. 2016). Ultimately, the claimant is responsible for providing evidence relating to her RFC, and the Commissioner is responsible for developing the claimant’s “complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help [the claimant] get medical reports from [the claimant’s] own medical sources.” 20 C.F.R. § 416.945(a)(3). If, upon the findings of the ALJ, it is determined the claimant retains the RFC to perform past relevant work, he or she is not disabled. 20 C.F.R. §

416.920(a)(4)(iv); see also, Goff v.

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Related

Jones v. Astrue
619 F.3d 963 (Eighth Circuit, 2010)
Hurd v. Astrue
621 F.3d 734 (Eighth Circuit, 2010)
Martise v. Astrue
641 F.3d 909 (Eighth Circuit, 2011)
McCoy v. Astrue
648 F.3d 605 (Eighth Circuit, 2011)
Perkins v. Astrue
648 F.3d 892 (Eighth Circuit, 2011)
Diana Phillips v. Michael J. Astrue
671 F.3d 699 (Eighth Circuit, 2012)
Kirby v. Astrue
500 F.3d 705 (Eighth Circuit, 2007)
Cox v. Astrue
495 F.3d 614 (Eighth Circuit, 2007)

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