Neel v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedNovember 16, 2021
Docket3:20-cv-00359
StatusUnknown

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

Opinion

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

JANIE M. NEEL PLAINTIFF

V. No. 3:20-CV-00359-ERE

COMMISSIONER OF SOCIAL SECURITY DEFENDANT

ORDER Plaintiff, Janie Neel, appeals the final decision of the Commissioner of the Social Security Administration denying her Title II application for disability insurance benefits and for supplemental security income benefits under Title XVI of the Social Security Act. For reasons set out below, the Commissioner’s decision is AFFIRMED. I. BACKGROUND On January 15, 2018, Ms. Neel filed for benefits due to diabetes, back problems, hypothyroidism, Hashimoto’s disease, sleep apnea, anxiety, depression, post-traumatic stress disorder (“PTSD”), and hyperlipemia. Tr. 263, 309. Ms. Neel’s applications were denied initially and upon reconsideration. At Ms. Neel’s request, an administrative law judge (“ALJ”) held a hearing on September 16, 2019, where she appeared with her lawyer, and the ALJ heard testimony from Ms. Neel and her sister. Tr. 1015-1046. The ALJ issued a decision

on April 27, 2020 finding that Ms. Neel was not disabled. Tr. 60-74. The Appeals Council denied Ms. Neel’s request for review, making the ALJ’s decision the Commissioner’s final decision. Tr. 1-4.

Ms. Neel, who was forty-three years old at the time of the hearing, has a GED, and past relevant work experience as a machinist, convenience store cashier, and housekeeper. Tr. 93, 116-119, 263.

II. THE ALJ’S DECISION1 The ALJ found that Ms. Neel, who has not engaged in substantial gainful activity since June 9, 2016, has the following severe impairments: Schmorl’s nodes (spinal disc herniation) at T12, degenerative disc disease of the lumbar and cervical

spine, osteoarthritic changes at the left sacroiliac joint and right foot, diabetes, hypothyroidism, obesity, depression, anxiety, borderline personality disorder, and PTSD. Tr. 63. However, the ALJ found that Ms. Neel did not have an impairment

or combination of impairments meeting or equaling an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1. Tr. 63-64. The ALJ found that Ms. Neel has the residual functional capacity (“RFC”) to perform sedentary work with the following restrictions. She can lift/carry 10 pounds

1The 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. §§ 416.920(a)-(g). occasionally and lesser weight frequently. In an eight-hour day, with normal breaks, she can stand one hour at a time, for a total of two hours with normal breaks; walk

fifteen minutes at a time for a total of one hour; and sit two hours at a time for a total of eight hours. Ms. Neel can occasionally reach overhead and she can frequently reach in all other directions. She also can occasionally push/pull weight; climb ramps

and stairs, but never ladders, ropes, or scaffolds; operate foot controls; balance, stoop, kneel, crouch, and crawl. She should not work at unprotected heights. She can tolerate a loud noise environment; occasional exposure to moving mechanical parts; frequent exposure to dust/odors/fumes and pulmonary irritants, extreme heat, and

vibrations. She can carry out simple instructions, but she would struggle with detailed instructions. She also can perform simple, routine tasks, with occasional public, coworker, and supervisor contact. Tr. 66.

In response to a vocational interrogatory, the vocational expert (“VE”) informed the ALJ that jobs available with these limitations included bonder, patcher, and sealer. Tr. 405-410. The ALJ determined that Ms. Neel could perform a significant number of jobs existing in the national economy and found she was not

disabled. Tr. 74. 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. Ms. Neel’s Arguments for Reversal Ms. Neel asserts that the ALJ’s credibility analysis was insufficient under

Polaski v. Heckler, 739 F.2d 1320, 1322 (8th Cir. 1984). Doc. 18 at p. 13. Ms. Neel contends that the ALJ simply paid lip-service to the “Polaski factors.” Id. “When evaluating a claimant’s subjective complaints of pain, the ALJ must

consider objective medical evidence, the claimant’s work history, and other evidence relating to (1) the claimant’s daily activities; (2) the duration, frequency, and intensity of the pain; (3) precipitating and aggravating factors; (4) the dosage,

effectiveness, and side effects of medication; and (5) the claimant’s functional restrictions.” Schwandt v. Berryhill, 926 F.3d 1004, 1012 (8th Cir. 2019) (citing Polaski v. Heckler, 739 F.2d 1320, 1322 (8th Cir. 1984)). An ALJ does not need to

explicitly discuss each of these “Polaski factors,” and can reject complaints which are inconsistent with the evidence as a whole. Id. A reviewing court “will defer to an ALJ’s credibility finding as long as the ALJ explicitly discredits a claimant’s testimony and gives a good reason for doing so.” Wildman v. Astrue, 596 F.3d 959,

968 (8th Cir. 2010) (citation omitted). The Court finds that substantial evidence supports the ALJ’s decision to discount Ms. Neel’s complaints. In assessing Ms. Neel’s subjective complaints of

pain, the ALJ considered numerous facts from the record as a whole and noted several inconsistencies. After a thorough recitation of Ms. Neel’s medical history, the ALJ noted that Ms. Neel’s “statements concerning the intensity, persistence and limiting effects of

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Related

Halverson v. Astrue
600 F.3d 922 (Eighth Circuit, 2010)
Wildman v. Astrue
596 F.3d 959 (Eighth Circuit, 2010)
Slusser v. Astrue
557 F.3d 923 (Eighth Circuit, 2009)
Moore v. Astrue
572 F.3d 520 (Eighth Circuit, 2009)
Tracy Milam v. Carolyn W. Colvin
794 F.3d 978 (Eighth Circuit, 2015)
Timothy Brown v. Carolyn W. Colvin
825 F.3d 936 (Eighth Circuit, 2016)

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Neel v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/neel-v-social-security-administration-ared-2021.