Jordan v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedJune 2, 2022
Docket4:21-cv-00359
StatusUnknown

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

Bluebook
Jordan v. Social Security Administration, (E.D. Ark. 2022).

Opinion

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

HEATHER JORDAN PLAINTIFF

V. CASE NO. 4:21-CV-00359-JM-ERE

COMMISSIONER of SOCIAL SECURITY ADMINISTRATION DEFENDANT

RECOMMENDED DISPOSITION

This Recommended Disposition (“Recommendation”) has been sent to United States District Judge James M. Moody, Jr. Either party may file written objections to this Recommendation. Objections should be specific and should include the factual or legal basis for the objection. To be considered, objections must be received in the office of the Court Clerk within 14 days of this Recommendation. If no objections are filed, Judge Moody can adopt this Recommendation without independently reviewing the record. By not objecting, parties may also waive the right to appeal questions of fact. I. INTRODUCTION On October 5, 2018, Heather Jordan applied for Supplemental Security Income (“SSI”) under Title XVI of the Social Security Act (“The Act”), alleging disability beginning June 30, 2008. (Tr. at 10). Her claims were denied both initially and upon reconsideration. Id. After conducting a hearing on May 8, 2020, an Administrative Law Judge (“ALJ”) denied Ms. Jordan’s application on August 5, 2020. (Tr. at 22). Following the ALJ’s order, Ms. Jordan sought review from the

Appeals Council, which denied her request for review. (Tr. at 1). Ms. Jordan seeks judicial review of the ALJ’s decision, which now stands as the Commissioner’s final decision.

For the reasons stated below, the Court should affirm the decision of the Commissioner. II. THE COMMISSIONER’S DECISION The ALJ found that Ms. Jordan had not engaged in substantial gainful activity

since the application date of October 5, 2018.1 (Tr. at 12). At Step Two of the familiar five-step analysis,2 the ALJ found that Ms. Jordan had the following severe impairments: fibromyalgia syndrome, minimal degenerative changes of the thoracic

spine, polyarthritis, and epilepsy/seizure disorder. Id.

1 SSI benefits are not payable for a period prior to a claimant’s application, and the relevant time period for determining whether SSI benefits are payable begins on the date the application is filed. Cruse v. Bowen, 867 F.2d 1183, 1185 (8th Cir. 1989).

2 Using a five-step sequence, the ALJ determines: (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. § 416.920(a)–(g). After finding Ms. Jordan’s impairments did not meet or equal a listed impairment, the ALJ determined that she had the residual functional capacity

(“RFC”) to perform work at the sedentary exertional level, except that: (1) she can occasionally climb ramps and stairs, but can never climb ladders, ropes, or scaffolds; (2) she can occasionally stoop, kneel, crouch, and crawl; (3) she can frequently but

not constantly reach, handle, and finger bilaterally; and (4) she must avoid concentrated exposure to temperature extremes, humidity, and hazards, including no driving as a part of work. (Tr. at 14). Relying on the testimony of a Vocational Expert (“VE”), the ALJ found that

Ms. Jordan’s RFC would allow her to perform jobs that exist in significant numbers in the national economy, including photo copy machine operator, collator operator, content checker, laminating machine off bearer, and blending tank tender helper.

(Tr. at 21). Thus, the ALJ concluded that Ms. Jordan was not disabled. (Tr. at 22). III. DISCUSSION A. Standard of Review In this appeal, the Court must review the Commissioner’s decision for legal

error and determine whether the decision is supported by substantial evidence on the record as a whole. Brown v. Colvin, 825 F.3d 936, 939 (8th Cir. 2016) (citing Halverson v. Astrue, 600 F.3d 922, 929 (8th Cir. 2010)). “Substantial evidence” in

this context means “enough that a reasonable mind would find [the evidence] adequate to support the ALJ’s decision.” Slusser v. Astrue, 557 F.3d 923, 925 (8th Cir. 2009) (citation omitted). In making this determination, the Court must consider

not only evidence that supports the Commissioner’s decision, but also evidence that supports a contrary outcome. Milam v. Colvin, 794 F.3d 978, 983 (8th Cir. 2015). The Court will not reverse the Commissioner’s decision, however, “merely because

substantial evidence exists for the opposite decision.” Long v. Chater, 108 F.3d 185, 187 (8th Cir. 1997) (citation omitted). B. Ms. Jordan’s Arguments on Appeal Ms. Jordan argues that the ALJ’s decision is not supported by substantial

evidence. She argues that the ALJ erred by: (1) determining that her mental impairments were not severe; (2) failing to properly evaluate a medical opinion from her treating physician; (3) relying “exclusively” on the opinions of non-examining

state agency consultants; (4) disregarding testimony from third parties about her symptoms; (5) failing to properly analyze her fibromyalgia symptoms; (6) failing to develop the record by seeking an opinion from a treating physician; (7) failing to provide a “function-by-function” assessment in determining her RFC; and (8) failing

to consider the combination of all of her impairments in determining her RFC. Ms. Jordan also presents a host of arguments concerning the system in place for determining disability. She claims that “[t]he process by which the agency

determines disability is neither logical nor rational, fails to provide substantive due process, results in decisions that are arbitrary and capricious and in unequal treatment for similarly situated claimants.” Doc. 12 at 2. She also claims that the

“regulations and policies for determining disability are unconstitutionally vague” and “leave too much discretion to ALJs[.]” Id. The Court will consider each of these claims separately.

1. Claim 1: Severity of Mental Impairments Ms. Jordan claims that the ALJ erred in determining her mental impairments were not severe at Step Two. In particular, Ms. Jordan asserts the ALJ did not conduct a meaningful analysis of her impairments and instead “simply deferr[ed] to

the unsupported opinions of the DDS consultants.” Doc. 12 at 8. She argues that the reports from prior consultative examinations in 2009 and 2014 show a longitudinal picture of her significant psychological difficulties, and the ALJ erred by not

considering them in the analysis. The Court disagrees and finds that substantial evidence on the record as a whole supports the ALJ’s finding that Ms. Jordan’s mental impairments were not severe. An impairment is considered non-severe if it does not significantly limit a

claimant’s ability to do basic work activities. 20 C.F.R.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Halverson v. Astrue
600 F.3d 922 (Eighth Circuit, 2010)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Wilburn v. Astrue
626 F.3d 999 (Eighth Circuit, 2010)
Buckner v. Astrue
646 F.3d 549 (Eighth Circuit, 2011)
Terri Anderson v. Michael J. Astrue
696 F.3d 790 (Eighth Circuit, 2012)
Slusser v. Astrue
557 F.3d 923 (Eighth Circuit, 2009)
Tracy Milam v. Carolyn W. Colvin
794 F.3d 978 (Eighth Circuit, 2015)
Timothy Brown v. Carolyn W. Colvin
825 F.3d 936 (Eighth Circuit, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Jordan v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jordan-v-social-security-administration-ared-2022.