Lafontaine v. Commissioner of Social Security

CourtDistrict Court, S.D. Mississippi
DecidedSeptember 28, 2022
Docket1:21-cv-00167
StatusUnknown

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

Bluebook
Lafontaine v. Commissioner of Social Security, (S.D. Miss. 2022).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF MISSISSIPPI SOUTHERN DIVISION

RHONDA L. LAFONTAINE PLAINTIFF

v. CIVIL ACTION NO. 1:21-cv-167-TBM-RPM

COMMISSIONER OF SOCIAL SECURITY DEFENDANT

ORDER ADOPTING REPORT AND RECOMMENDATION AND AFFIRMING THE FINAL DECISION OF THE COMMISSIONER

Before the Court is the Report and Recommendation [13] entered by United States Magistrate Judge Robert P. Myers on June 6, 2022. Rhonda Lafontaine appeals the final decision of the Commissioner of Social Security Administration denying her claim for disability insurance benefits after suffering a stroke in 2016. Magistrate Judge Myers recommends that the Court affirm the Commissioner’s final decision. Lafontaine timely filed her Objections [14] to the Report and Recommendation objecting to the administrative law judge’s disability determination because of a drafting error in the consideration of Dr. Ethel Hetrick’s 2016 and 2019 opinions as well as the Magistrate Judge’s conclusion that the ALJ did not err in her evaluation of Dr. Hetrick’s opinions. After due consideration of the Report and Recommendation, Lafontaine’s submissions, and the relevant legal authority, the Court finds that Lafontaine’s Objections [14] should be overruled and the Report and Recommendation [13] should be adopted as the opinion of this Court. I. BACKGROUND Lafontaine applied for disability insurance benefits after she suffered a stroke alleging a disability onset date of January 27, 2016. [6], pps. 17; 23. The agency denied Lafontaine’s claim on initial review and on reconsideration. Id. at 17. An administrative law judge (“ALJ”) held a hearing at which Lafontaine and an impartial vocational expert testified. Id. The ALJ considered the evidence put forth and decided Lafontaine is not disabled under the Social Security Act. Id. at 32. In the ALJ’s decision, she first determined that Lafontaine meets the insured status

requirements of the Social Security Act through the requisite time period and had not engaged in substantial gainful activity since January 27, 2016. [6], pg. 19. Next, the ALJ determined that Lafontaine suffers from the following severe impairments: left homonymous hemianopsia, obesity, borderline intellectual functioning, anxiety, and depression. Id. at 19–20. Because the ALJ found a severe impairment, the ALJ moved on to the third step and concluded that Lafontaine does not have an impairment or combination of impairments that meets or medically equals one of the listed

impairments at 20 C.F.R. pt. 404, subpt. P, app. 1. Id. at 21. Since the ALJ found Lafontaine was not impaired, she moved on to step four and determined that Lafontaine had the residual functional capacity (“RFC”) “to perform light work as defined in 20 C.F.R. § 404.1567(b) except the claimant should avoid more than occasional exposure to hazards including moving machinery and unprotected heights; she is limited to performing simple, routine tasks in which she has no more than occasional interaction with the public or coworkers; and she should not be required to drive as part of her work duties.” Id. at 22–

23. Based on this RFC, the ALJ found that “[t]he claimant is unable to perform any past relevant work.” Id. at 30. At the last step, the ALJ found that “[c]onsidering the claimant’s age, education, work experience and [RFC], there are jobs that exist in significant numbers in the national economy that the claimant can perform.” Id. at 31. Thus, the ALJ concluded at step five that Lafontaine is not disabled within the meaning of the Social Security Act. Id. at 32. The Appeals Council denied review and the ALJ’s decision became the final decision of the Commissioner. Id. at 11. Lafontaine then appealed the Commissioner’s decision to this Court. [1]. The ALJ considered numerous examinations and opinions from various medical

professionals. [6], pps. 20–32. At issue are two psychological evaluations performed by Ethel Hetrick, PhD. [14], pg. 1. Dr. Hetrick performed the first evaluation on October 20, 2016, and found Lafontaine has “the mental capacity to perform routine, repetitive tasks.” [6], pps. 549–51. Then, on April 10, 2019, Dr. Hetrick included a qualification that Lafontaine could “perform routine, repetitive tasks, but not in a competitive work setting due to poor working memory, slowed mental processing and anxiety.” Id. at 771 (emphasis added). Dr. Hetrick made this conclusion based on

Lafontaine’s husband’s report of irritability. Id. at 771–72. In the ALJ’s decision, the ALJ repeated the same findings regarding Lafontaine’s alleged inability to work in a “competitive setting” when referring to the 2016 evaluation. [6], pg. 30. Although, that restrictive finding was only in the 2019 evaluation opinion. Id. at 771. Lafontaine appealed alleging that the ALJ did not properly weigh the opinions of consultative examiner Dr. Hetrick. [13], pg. 2. Magistrate Judge Myers reviewed Lafontaine’s appeal and recommended that the decision

of the Commissioner be affirmed. [13]. Although the ALJ’s decision mistakenly used the findings of Dr. Hetrick’s 2019 evaluation when referring to the Dr. Hetrick 2016 evaluation, the ALJ found both the 2016 and 2019 opinions unpersuasive. [6], pg. 30. The ALJ used the more stringent opinion, and mistakenly repeated the relevant findings when referring to the 2016 evaluation. Id. Magistrate Judge Myers found that “[t]his appears to be a mere drafting error.” [13], pg. 6. Ultimately, Magistrate Judge Myers found the “ALJ’s conclusion that Lafontaine could perform simple, routine tasks in a work setting is supported by substantial evidence in the record.” [13], pg. 8. Lafontaine timely objected to the Report and Recommendation. [14]. In her Objection,

Lafontaine argues that the ALJ’s confusion between the 2016 and 2019 opinions was more than a mere drafting error and that the ALJ erred in determining her RFC assessment because the ALJ did not adequately review the opinions of Dr. Hetrick. [14], pg. 1. II. STANDARD OF REVIEW It is well-settled that “[p]arties filing objections must specifically identify those findings objected to.” Battle v. U.S. Parole Comm’n, 834 F.2d 419, 421 (5th Cir. 1987) (alteration in original)

(quoting Nettles v. Wainwright, 677 F.2d 404, 410 n.8 (5th Cir. 1982)). The Court must review any objected-to portions of a report and recommendation de novo. Such a review means that the Court will consider the record that has been developed before the Magistrate Judge and make its own determination on the basis of that record. United States v. Raddatz, 447 U.S. 667, 675, 100 S. Ct. 2406, 65 L. Ed. 2d 424 (1980). The Court need not consider frivolous, conclusive, or general objections. Johansson v. King, No. 5:14-cv-96-DCB, 2015 WL 5089782, at *2 (S.D. Miss. Aug. 27, 2015) (citing Battle, 834 F.2d at 421). Additionally, “[m]erely reurging the allegations in the

petition or attacking the underlying conviction is insufficient to receive de novo review.” Id. When a de novo review is not warranted, the Court need only review the findings and recommendation and determine whether they are either clearly erroneous or contrary to law. United States v. Wilson, 864 F.2d 1219, 1221 (5th Cir. 1989).

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Lafontaine v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lafontaine-v-commissioner-of-social-security-mssd-2022.