Jordan v. Commissioner of Social Security

CourtDistrict Court, M.D. Pennsylvania
DecidedMarch 23, 2023
Docket1:21-cv-01975
StatusUnknown

This text of Jordan v. Commissioner of Social Security (Jordan v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jordan v. Commissioner of Social Security, (M.D. Pa. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

JAMES LOUIS JORDAN, : Civil No. 1:21-cv-01975 : Plaintiff : (Magistrate Judge Carlson) : v. : : KILOLO KIJAKAZI, : Acting Commissioner of Social Security, : : Defendant :

MEMORANDUM OPINION

I. Introduction For Administrative Law Judges (ALJs), Social Security disability determinations frequently entail an informed assessment of competing medical opinions coupled with an evaluation of a claimant’s subjective complaints. Once the ALJ completes this task, on appeal it is the duty and responsibility of the district court to review these ALJ findings, judging the findings against a deferential standard of review which simply asks whether the ALJ’s decision is supported by substantial evidence in the record, see 42 U.S.C. § 405(g); Johnson v. Comm’r of Soc. Sec., 529 F.3d 198, 200 (3d Cir. 2008); Ficca v. Astrue, 901 F. Supp.2d 533, 536 (M.D. Pa. 2012), a quantum of proof which “does not mean a large or considerable amount of evidence, but rather such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Pierce v. Underwood, 487 U.S. 552, 565 (1988). This informed assessment by the ALJ, however, must be accompanied by “a clear and satisfactory explication of the basis on which it rests.”

Cotter v. Harris, 642 F.2d 700, 704 (3d Cir. 1981). Thus, the Social Security Act and case law construing the Act place a duty of articulation upon ALJ’s which is essential to informed evaluation of disability determinations on appeal.

We are reminded of these guiding tenets of Social Security practice as we turn to this case. In the instant case, an ALJ denied James Jordan’s disability application, which alleged disability beginning on July 27, 2019. However, in reaching this result the ALJ did not include a provision in the residual functional capacity (RFC) to

account for Jordan’s use of a cane to ambulate because the ALJ found the cane was not medically necessary according to SSR 96–9p. The ALJ reached this conclusion without adequately addressing the evidence which indicated that some use of a cane

was medically necessary for Jordan. Thus, we conclude that the ALJ failed sufficiently articulate this finding in light of a body of countervailing evidence regarding Jordan’s use of a cane. Specifically, in January 2020, Jordan was referred for a replacement single point cane by his treating doctor. (Tr. 611). The record also

reveals that in 2015 Jordan was prescribed a cane. (Tr. 203). Additionally, the record is replete with references to Jordan’s use of a cane to ambulate and his antalgic gait. (Tr. 628, 629, 646, 680-724, 754, 755, 770, 824, 843). In our view, given the evidence which reveals that Jordan was referred for a cane and routinely used that cane, more is needed here to justify the ALJ’s decision

which fashioned an RFC for Jordan that wholly discounted his use of a cane and instead required him “to perform light work as defined in 20 CFR 404.1567(b) except he may occasionally balance, stoop, kneel, crouch, crawl, and climb ramps

or stairs, but must never climb ladders, ropes, or scaffolds . . .” (Tr. 22). Indeed, in similar circumstances we have held that when an ALJ crafts an RFC for a claimant that includes significant mobility requirements, without accounting for their need for an assistive device, a remand is warranted. See Dieter v. Saul, No. 1:19-CV-1081,

2020 WL 2839087, at *9 (M.D. Pa. June 1, 2020). Accordingly, for the reasons set forth below, we will remand this case for further consideration by the Commissioner. II. Factual Background and Procedural History

Because we have determined that a remand is necessary due to the failure to sufficiently articulate a rationale for why Jordan’s use of a cane was not accounted for in the RFC, we will focus upon this issue when assessing the record. On August 20, 2019, Jordan applied for disability and supplemental security

insurance benefits pursuant to Title II of the Social Security Act, alleging an onset of disability beginning on July 27, 2019. (Tr. 16). Jordan was 49 years old at the time of the alleged onset of his disability. (Tr. 31). Jordan is no longer in the younger

individual age category and is now in the closely approaching advanced age category. (Id.) Jordan had prior employment as a janitor, electrician helper, and a warehouse supervisor. (Id.)

At a disability hearing conducted on January 14, 2021, Jordan testified concerning his use of a cane. (Tr. 49-50). Jordan explained he uses a cane for “balance and stability” and uses a cane in his home. (Tr. 49). Jordan also explained

he started using a cane when he moved into his home approximately four years prior to when the hearing was held. (Id.) Jordan testified that he did not use a cane at work. (Tr. 49-50). Jordan stopped working as a janitor in July 2019. (Tr. 180). The records from the Department of Veterans Affairs, specifically the

Lebanon VA Medical Center, indicate that Jordan can manage toileting, grooming, and self-feeding on his own, but his wife helps him into and out of the shower, washes his back, and sometimes helps him with getting dressed. (Tr. 829, 843).

These treatment notes indicate Jordan ambulates using a single point cane and can manage the steps into his family room by holding onto both rails. (Tr. 829). In Jordan’s Function Report, he stated he needs help getting in and out of the bathtub and going up and down stairs. (Tr. 198). Jordan explained he takes breaks

when doing tasks such as washing dishes and performing light yard work to relieve himself of the pain from moving too much. (Tr. 199). He also explained that when he and his wife go grocery shopping, he normally remains in the car while she goes

into the store. (Tr. 200). Dr. Bowers, a treating source, referred Jordan to Dr. Williams for evaluation and treatment for his low back pain. Dr. Williams’ treatment records indicate she

treated Jordan for a period of approximately seven or so months. (Tr. 680-724). During this time Dr. Williams consistently referenced Jordan’s use of a cane and his antalgic gate. (Id.) Jordan was treated by Dr. Williams from the end of January 2020

until September 2020. (Id.) Also, on January 27, 2020, Dr. Williams noted that Jordan’s “pain level increased with standing, prolonged sitting, or bending.” (Tr. 677). Treatment notes from the Lebanon VA Medical Center also contain several

references to Jordan’s use of a cane, difficulty ambulating, and his antalgic gate. (Tr. 754, 755, 770, 824, 843). A treatment note entered on November 16, 2020, by a nurse practitioner-trainee at the Lebanon VA Medical Center indicates that Jordan

“ambulated into the room using a cane and with great difficulty due to ongoing persistent low back pain that he is currently being seen by his PCP for.” (Tr. 754). The nurse-practitioner-trainee also indicated Jordan has “acute onset of low back pain for several weeks, struggling to ambulate without use of cane, is followed by

PCP for back pain[.]” (Tr. 755). Another progress note signed by a social worker on August 21, 2020, indicates that Jordan uses a cane when ambulating according to his spouse. A behavioral health care manager September 2, 2020, stated that Jordan

“ambulates slowly with cane[.]” (Tr. 824).

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Jordan v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jordan-v-commissioner-of-social-security-pamd-2023.