Matthew Stephen Snow v. Social Security Administration, Commissioner
This text of Matthew Stephen Snow v. Social Security Administration, Commissioner (Matthew Stephen Snow v. Social Security Administration, Commissioner) 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.
Opinion
IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION
MATTHEW STEPHEN SNOW PLAINTIFF
V. No. 4:25-CV-00423-JM-ERE
SOCIAL SECURITY ADMINISTRATION, Commissioner DEFENDANT
ORDER1
Plaintiff Matthew Snow appeals the Social Security Administration Commissioner’s final decision denying his application for disability benefits. For the reasons set out below, the Commissioner’s decision is AFFIRMED. I. Background In 2022, Mr. Snow filed an application for benefits due to depression, attention deficit disorder, bipolar disorder, autism, post-traumatic stress disorder (“PTSD”), and a nervous breakdown. Tr. 13, 190, 200, 249. Mr. Snow’s claim was denied initially and upon reconsideration. At Mr. Snow’s request, an Administrative Law Judge (“ALJ”) held a hearing on April 10, 2024, where Mr. Snow appeared with his lawyer, and the ALJ heard testimony from Mr. Snow and a vocational expert (“VE”). Tr. 29-62. On May 21, 2024, the ALJ issued a decision finding that Mr. Snow was not disabled. Tr. 13-23. The Appeals
1 The parties consented in writing to the jurisdiction of a United States Magistrate Judge. Doc. 13. Council denied Mr. Snow’s request for review, making the ALJ’s decision the Commissioner’s final decision. Tr. 1-3.
Mr. Snow, who was forty-seven years old at the time of the hearing, attended some college and has past relevant work experience as an assistant manager and in fragrance retail sales. Tr. 21, 55.
II. The ALJ’s Decision2 The ALJ found that Mr. Snow had not engaged in substantial gainful activity since the alleged onset date of March 10, 2020. Tr. 15. The ALJ also concluded that Mr. Snow had the following severe impairments: generalized anxiety disorder,
PTSD, depression, autism, and agoraphobia. Id. However, the ALJ concluded that Mr. Snow did not have an impairment or combination of impairments that met or equaled an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1. Tr. 16.
According to the ALJ, Mr. Snow had the residual functional capacity (“RFC”) to perform the full range of work at all exertional levels, with the following limitations: (1) only simple tasks with simple work instructions and procedures; (2)
2 The ALJ followed the required sequential analysis to determine: (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; and (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. § 404.1520(a)-(g); 20 C.F.R. § 416.920(a)-(g). can adapt to changes in work that are simple, predictable, and easily explained; and (3) only occasional contact with co-workers, supervisors, and the public. Tr. 18.
In response to hypothetical questions incorporating the above limitations, the VE testified that a substantial number of potential jobs were available in the national economy that Mr. Snow could perform, including laundry worker and cleaner. Tr.
22, 59. Accordingly, the ALJ determined that Mr. Snow was not disabled. 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. Mr. Snow’s Arguments for Reversal Mr. Snow contends that the Commissioner’s decision is not supported by
substantial evidence because the ALJ failed to properly evaluate and explain the reasons for finding treating therapist APRN Danielle Jenkins’ opinions unpersuasive. Doc. 9. After carefully considering the record as a whole, I affirm the
Commissioner. C. Analysis Mr. Snow alleges that the ALJ erred when addressing Nurse Jenkins’ opinions regarding his mental impairments. Id. Mr. Snow points out that Nurse
Jenkins indicated on a medical opinion questionnaire that he has marked limitations related to sustained concentration and persistence, social interaction, and adaptation. Doc. 9, Tr. 740-741. She also provided a paragraph summary of Mr.
Snow’s mental impairments and their affect on his activities of daily living. Tr. 741. However, the ALJ found that Nurse Jenkins’ opinions were not persuasive because they were: not supported by or consistent with the record; vague; contradicted by the mental exams she performed; and inconsistent with Mr. Snow’s
activities of daily living. Tr. 21. The ALJ then pointed to numerous places in the record supporting these findings. For example, Nurse Jenkins’ treatment notes repeatedly indicated unremarkable, normal behavior and thought content by Mr.
Snow as well as his reports to Nurse Jenkins that he was doing “alright.” Tr. 509, 533, 562, 566, 574, 578, 583, 588, 610, 622, 660. A treatment provider’s statements may be discounted if they are inconsistent with the overall assessment of the
treatment provider or the opinions of others, especially where the other opinions are supported by more or better medical evidence. Prosch v. Apfel, 201 F3.d 1010, 1013-14 (8th Cir. 2007); House v. Astrue, 500 F.3d 741, 744 (8th Cir. 2007) (an
ALJ is not required to give controlling weight to the opinion of a treating physician if the opinion is inconsistent with the other substantial evidence in the record). The ALJ properly noted that Mr. Snow was never psychiatrically hospitalized for his mental impairments and that “treatment and therapy were regular in nature without
reports of exacerbation . . . .” Tr. 19. In fact, Mr. Snow advised Nurse Jenkins that he was improving with therapy and medication. Tr. 563. Improvement in condition supports an ALJ’s finding that a claimant is not disabled. See Duvall v. Bisignano,
No. 4:25-cv-00120 KGB-PSH, 2025 WL 1812626, n.6 (E.D. Ark. July 1, 2025); see Locher v. Sullivan, 968 F.2d 725, 728 (8th Cir. 1992).
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