Messmer v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedJune 30, 2021
Docket4:20-cv-01330
StatusUnknown

This text of Messmer v. Social Security Administration (Messmer 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
Messmer v. Social Security Administration, (E.D. Ark. 2021).

Opinion

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

TAMMY MESSMER PLAINTIFF

V. NO. 4:20-cv-01330-KBG-ERE

COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION DEFENDANT

RECOMMENDED DISPOSITION

This Recommended Disposition (Recommendation) has been sent to United States District Judge Kristine G. Baker. Either party may file written objections to this Recommendation. If objections are filed, they 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 Baker 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 August 13, 2015, Tammy Messmer filed a Title II application for disability and disability insurance benefits and a Title XVI application for supplemental security income benefits. (Tr. at 106). In both applications, she alleged disability

1 beginning on June 1, 2015. Id. An administrative law judge (ALJ) denied her applications in a decision dated January 19, 2018. (Tr. at 116). That decision became

final when Ms. Messmer failed to file a timely appeal. (Tr. at 11). On March 2, 2018, Ms. Messmer again filed both a Title II and a Title XVI application for benefits. Id. She alleged disability beginning on June 2, 2015. Id.

After her applications were denied initially and upon reconsideration, a second ALJ conducted a hearing on January 15, 2020. Id. At the hearing, Ms. Messmer requested that the ALJ amend her alleged onset date to March 2, 2018. Id. The ALJ declined to amend the onset date. Id.

In a decision dated February 28, 2020, the second ALJ declined to reopen the prior decision, and he found that Ms. Messmer was not disabled from January 20, 2018 through February 28, 2020, the date of the decision.1 (Tr. at 11-23). The

Appeals Council found no reason to disturb the second ALJ’s decision. (Tr. at 1). Thus, the second ALJ’s decision now stands as the final decision of the Commissioner. For the reasons stated below, this Court should reverse the second ALJ’s

decision and remand for further review.

1 The second ALJ explained that the new relevant time-period began on January 20, 2018, the day after the first ALJ’s final decision. (Tr. at 11).

2 II. The Commissioner=s Decision: The first ALJ found that Ms. Messmer, who was born on November 18, 1969,

had the following severe impairments: degenerative disc disease, right shoulder impairment, and anxiety. 2 (Tr. at 108). After finding that Ms. Messmer’s impairments did not meet or equal a Listing, the first ALJ assigned a residual

functional capacity (RFC) for sedentary work with postural limitations. (Tr. at 110). Next, he determined that Ms. Messmer was unable to perform any of her past relevant work. (Tr. at 114). Based on testimony from a Vocational Expert (VE), and considering Ms. Messmer’s age, education, work experience, and RFC, the first ALJ

found that there were jobs in the national economy that Ms. Messmer could perform, such as fishing reel assembler and machine tender. (Tr. at 115). Therefore, the first ALJ found that Ms. Messmer was not disabled. Id.

In the decision dated February 28, 2020, the second ALJ found that Ms. Messmer had not engaged in substantial gainful activity since January 20, 2018. (Tr. at 14). He determined that she had the following severe impairments: disorders of

2 The ALJ followed the required five-step 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 (Listing); (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), 416.920(a)-(g).

3 the back, right fifth closed metatarsal fracture, and adjustment disorder with anxiety. Id.

After finding that Ms. Messmer’s impairments did not meet or equal a Listing (Tr. at 14), the second ALJ determined that she was able to perform work at the light exertional level, with exceptions: (1) she is limited to occasional stooping,

crouching, and balancing; (2) she can occasionally climb ladders, ropes or scaffolds, and can occasionally climb ramps or stairs; (3) she cannot engage in frequent overhead reaching with the right upper extremity; (4) she is limited to semi-skilled work, where interpersonal contact is routine but superficial, and where the

complexity of tasks is learned by experience and involves several variables and uses judgment within limits, and where the supervision required is little for routine but detailed for nonroutine tasks. (Tr. at 16).

The second ALJ next found that Ms. Messmer was capable of performing past relevant work as a production assembler, which is an unskilled, light RFC job. (Tr. at 21). At step five, the ALJ relied upon the testimony of the VE to find that, considering Ms. Messmer’s age educational work experience and RFC, jobs existed

in significant numbers in the national economy that she could perform, such as general inspector and electronics assembler, which are semi-skilled, light RFC jobs. (Tr. at 22). Therefore, the second ALJ found that Ms. Messmer was not disabled

4 from January 20, 2018 through February 28, 2020, the date of his decision. (Tr. at 22-23).

III. Discussion: A. Standard of Review The Court’s function on review is to determine whether the Commissioner’s

decision is supported by substantial evidence on the record as a whole and whether it is based on legal error. Miller v. Colvin, 784 F.3d 472, 477 (8th Cir. 2015); see also 42 U.S.C. § 405(g). While “substantial evidence” is that which a reasonable mind might accept as adequate to support a conclusion, “substantial evidence on the

record as a whole” requires a court to engage in a more scrutinizing analysis: “[O]ur review is more than an examination of the record for the existence of substantial evidence in support of the Commissioner’s decision; we also take into account whatever in the record fairly detracts from that decision.” Reversal is not warranted, however, “merely because substantial evidence would have supported an opposite decision.”

Reed v. Barnhart, 399 F.3d 917, 920 (8th Cir. 2005) (citations omitted). In clarifying the “substantial evidence” standard applicable to review of administrative decisions, the Supreme Court has explained: “And whatever the meaning of ‘substantial’ in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence . . . ‘is more than a mere scintilla.’”

5 Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (quoting Consolidated Edison Co. v. NLRB, 59 S. Ct. 206, 217 (1938)). “It means—and means only—‘such relevant

evidence as a reasonable mind might accept as adequate to support a conclusion.’” Id. It is not the task of this Court to review the evidence and make an independent

decision.

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Charles Miller v. Carolyn W. Colvin
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Gavin v. Heckler
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Messmer v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/messmer-v-social-security-administration-ared-2021.