Lamoureux v. Commissioner of Social Security Administration

CourtDistrict Court, M.D. Pennsylvania
DecidedMarch 9, 2021
Docket1:20-cv-00665
StatusUnknown

This text of Lamoureux v. Commissioner of Social Security Administration (Lamoureux v. Commissioner of Social Security Administration) 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
Lamoureux v. Commissioner of Social Security Administration, (M.D. Pa. 2021).

Opinion

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

COLT RUSSELL LAMOUREUX, : Civil No. 1:20-CV-665 : Plaintiff : : v. : (Magistrate Judge Carlson) : ANDREW SAUL, : Commissioner of Social Security, : : Defendant :

MEMORANDUM OPINION

I. Introduction

The Supreme Court has underscored for us the limited scope of our review when considering Social Security appeals, noting that: The phrase “substantial evidence” is a “term of art” used throughout administrative law to describe how courts are to review agency factfinding. T-Mobile South, LLC v. Roswell, 574 U.S. ––––, ––––, 135 S. Ct. 808, 815, 190 L.Ed.2d 679 (2015). Under the substantial- evidence standard, a court looks to an existing administrative record and asks whether it contains “sufficien[t] evidence” to support the agency’s factual determinations. Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S. Ct. 206, 83 L.Ed. 126 (1938) (emphasis deleted). And whatever the meaning of “substantial” in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence, this Court has said, is “more than a mere scintilla.” Ibid.; see, e.g., Perales, 402 U.S. at 401, 91 S. Ct. 1420 (internal quotation marks omitted). It means—and means only—“such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Consolidated Edison, 305 U.S. at 229, 59 S. Ct. 206. See Dickinson v. Zurko, 527 U.S. 150, 153, 119 S. Ct. 1816, 144 L.Ed.2d 143 (1999) (comparing the substantial-evidence standard to the deferential clearly- erroneous standard). Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019).

In the instant case, Colt Lamoureux, a younger worker who was in his 20s at the time of the alleged onset of his disability, applied for disability benefits under Title II of the Social Security Act on January 2, 2019, alleging that he had been disabled since February 26, 2013, due to back and hip injuries, obesity and mental

impairments. (Tr. 15-17). After a consideration of the medical records and opinion evidence, the Administrative Law Judge (“ALJ”) who reviewed this case concluded that Lamoureux could perform a range of sedentary work with limitations and denied this disability application. (Tr. 12-28).

Mindful of the fact that substantial evidence “means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion,’ ” Biestek, 139 S. Ct. at 1154, we find that substantial evidence supported the ALJ’s

findings in this case. Therefore, for the reasons set forth below, we will affirm the decision of the Commissioner denying this claim. II. Statement of Facts and of the Case

Colt Lamoureux applied for disability income benefits under Title II of the Social Security Act on January 2, 2019, alleging that he had been disabled since February of 2013, due to back and hip injuries, obesity, and mental impairments. (Tr. 15-17). Lamoureux was born in November of 1985, and was thus in his late 20s

at the time of the alleged onset of his disability, making him a younger worker under the Commissioner’s regulations. (Tr. 26). Lamoureux had previously served in the military, in the Army Airborne, and had suffered back and joint injuries as a result

of a parachute jump while in the service. (Tr. 22). The date of the alleged onset of his disability for Social Security purposes coincided with his discharge from the military and it was reported that Lamoureux had not worked since his discharge. (Tr.

22). The administrative record in this case confirmed that Lamoureux had experienced a significant service-related back injury, but also contained references to his ability to perform some sedentary work. Thus, a March 13, 2019, functional

capacity evaluation of Lamoureux conducted by ErgoScience concluded that Lamoureux could perform some work in the sedentary range. (Tr. 386-395).1 Likewise, treatment notes from the VA observed that Lamoureux could “perform

sedentary activity if he can use the speaker phone to communicate and can perform limited time on computer and/or reading.” (Tr. 587). For his part, Lamoureux has reported that, while his chronic back injuries and pain have severely reduced his level of activity, he is still able to do some farming, yard work and household tasks.

(Tr. 39-44, 177-184, 470). Lamoureux also reported that he can drive, walk short

1 While limiting Lamoureux to sedentary work, this report suggested that the plaintiff could not sustain this level of work during an 8 hour per day, 40-hour work week. The ALJ rejected that aspect of the ErgoScience report’s conclusions as inconsistent with Lamoureux’s activities of daily living, (Tr. 25), and Lamoureux has not specifically challenged this finding on appeal. distances, go out daily, shop, manage his finances, and occasionally hunt and fish, albeit with back discomfort. (Id.)

It is against this backdrop that a hearing was held on this disability application on October 4, 2019, where Lamoureux appeared and testified along with a Vocational Expert. (Tr. 32-68). In the course of the Vocational Expert’s testimony,

in response to hypothetical questions posed by the ALJ, the expert identified three sedentary jobs that Lamoureux could perform—table worker, bond semiconductor and security systems monitor. (Tr. 27, 62). The Vocational Expert further testified that there were approximately 36,000 positions available in the national economy in

these three fields. (Id.) Following this hearing, on November 15, 2019, the ALJ issued a decision denying this application for benefits, finding that Lamoureux remained capable of

performing a limited range of sedentary jobs in the national economy. (Tr. 12-28). In that decision, the ALJ first concluded that Lamoureux had not engaged in any substantial gainful activity since the date of the alleged onset of his disability. (Tr. 17). At Step 2 of the sequential analysis that governs Social Security cases, the ALJ

found that Lamoureux’s back and hip injuries, and related emotional disorders were severe impairments. (Id.) At Step 3, the ALJ determined that none of these impairments met or medically equaled the severity of one of the listed impairments.

(Tr. 18-21). Between Steps 3 and 4, the ALJ fashioned a residual functional capacity (“RFC”), which considered all of Lamoureux’s limitations from his impairments and

found that he could perform a range of sedentary work with some restrictions. (Tr. 21-26). In making this RFC determination, the ALJ considered all of the medical and opinion evidence in this case, as well as Lamoureux’s self-reported activities of

daily living. (Id.) While largely crediting Lamoureux’s assertions that he was unable to lead the very active lifestyle he enjoyed prior to his service-related injury, the ALJ noted that his activities of daily living and conservative medical treatment suggested that Lamoureux retained the ability to perform some sedentary work. (Id.)

Having arrived at this RFC assessment, the ALJ found at Step 4 that Lamoureux could not return to his past work, but concluded at Step 5 that there were a number of sedentary jobs in the national economy that he could perform. (Tr. 26-

28). In particular, consistent with the Vocational Expert’s testimony, the ALJ found that there were three sedentary jobs that Lamoureux could perform—table worker, bond semiconductor, and security systems monitor. The ALJ further determined that there were approximately 36,000 positions available in the national economy in

these three fields.

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Related

Consolo v. Federal Maritime Commission
383 U.S. 607 (Supreme Court, 1966)
Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Dickinson v. Zurko
527 U.S. 150 (Supreme Court, 1999)

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Lamoureux v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lamoureux-v-commissioner-of-social-security-administration-pamd-2021.