Meux v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedNovember 29, 2021
Docket2:20-cv-00188
StatusUnknown

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

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS DELTA DIVISION

EBONIE MEUX, on behalf of Jayden Dewayne Foster, a minor child PLAINTIFF

V. No. 2:20-CV-188-BSM-JTR

KILOLO KIJAKAZI, Commissioner Social Security Administration DEFENDANT

RECOMMENDED DISPOSITION

The following Recommended Disposition (“Recommendation”) has been sent to United States District Judge Brian S. Miller. 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 Miller 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 17, 2016, Plaintiff, Ebonie Meux (“Meux”), applied for childhood supplemental security income benefits on behalf of her minor child, Jayden Dewayne Foster (“Foster”). (Tr. at 15). Meux alleged that Foster’s disability began on November 1, 2015.1 Id. After conducting a hearing on April 16, 2019, the Administrative Law Judge (“ALJ”) denied Meux’s application for benefits on

October 18, 2019. (Tr. at 30). On July 22, 2020, the Appeals Council declined to review the ALJ’s decision. (Tr. at 1). Thus, the ALJ’s decision now stands as the final decision of the Commissioner, and Meux has requested judicial review.

For the reasons stated below, the Court should reverse the ALJ’s decision and remand for further review. II. The Commissioner’s Decision For minor child disability cases, an ALJ must follow a three-step sequential

evaluation. Under this framework, the ALJ is required to first determine if the minor is engaging in substantial gainful activity. 20 C.F.R. § 416.924. Next, the ALJ must decide if the impairment, or combination of impairments, is severe. Id. Finally, the ALJ must determine if the Plaintiff has an impairment that meets, medically equals,

or functionally equals a listed impairment. Id. For medical equivalence, the ALJ refers to the Child Listing of Impairments in Disability Evaluation. 20 C.F.R. Pt. 404, Subpt. P, Appx. 1. This is an index of

medical conditions and the signs or symptoms required for a minor to meet a Listing.

1 At the hearing, Meux amended the onset date to August 17, 2016, the application date. (Tr. at 57). For functional equivalence, a minor has met a Listing if his impairment or combination of impairments results in a “marked” limitation in two domains of

functioning, or an “extreme” limitation in one domain. 20 C.F.R. § 416.926. The six domains of functioning are: (1) acquiring and using information; (2) attending and completing tasks; (3) interacting and relating with others; (4) moving about and

manipulating objects; (5) caring for oneself; and (6) health and physical well-being. Id. The ALJ in this case found that Foster, who was born on November 20, 2009, had not engaged in substantial gainful activity since the application date of August

17, 2016. (Tr. at 18). He next determined that Foster had the following severe impairments: speech/language delay and borderline intellectual function. Id. The ALJ determined that Foster did not meet or medically equal a Listing.

(Tr. at 19). Finally, he determined that Foster did not have an impairment that functionally equaled the severity of the Listings; that is, he concluded that Foster did not have severe impairments that resulted in two marked limitations or one extreme limitation in the six functional domains. (Tr. at 18–29). He found that: (1) Foster had

less than a marked limitation in acquiring and using information; (2) Foster had less than a marked limitation in attending and completing tasks; (3) Foster had less than a marked limitation in interacting and relating with others; (4) Foster had no

limitation in moving about and manipulating objects; (5) Foster had no limitation in the ability to care for himself; and (6) Foster had less than a marked limitation in health and physical well-being. Id. Therefore, the ALJ determined that Foster was

not disabled from August 17, 2016 through October 18, 2019, which was the date of the ALJ’s decision. (Tr. at 30). 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.’” 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. Neither is it to reverse the decision of the ALJ because there is evidence in the record which contradicts his findings. The test is whether there is substantial evidence in the record as a whole which supports the decision of the ALJ. Miller, 784 F.3d at 477.

B. Meux=s Arguments on Appeal Meux contends that the evidence supporting the ALJ’s decision to deny benefits is less than substantial. She argues that the ALJ erred when he found that Foster had less than marked limitations in the domains of: (1) acquiring and using

information; (2) attending and completing tasks; and (3) interacting and relating with others. For the following reasons, the Court finds support for reversal. Foster suffered from some speech and behavior problems that were

documented by his teachers and his family doctor. (Tr. at 285–306, 322–329, 383). He repeated kindergarten, and he was written up for behavior problems several times in the second grade. Id. A speech pathologist examined Foster in March 2016, and found that his oral expression skills were severely delayed. (Tr. at 361–363). In 2017, Foster’s family doctor referred him for speech, behavior and learning support. (Tr. at 383). Two consultative examinations were held, one in 2016 and one in 2017,

by Kenneth Jones, Ph.D. (Tr. at 365–374). Dr.

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