Northcutt v. O'Malley

CourtDistrict Court, E.D. Missouri
DecidedSeptember 6, 2024
Docket4:24-cv-00200
StatusUnknown

This text of Northcutt v. O'Malley (Northcutt v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Northcutt v. O'Malley, (E.D. Mo. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

ANGELA NORTHCUTT, ) ) Plaintiff, ) ) v. ) No. 4:24 CV 200 RWS ) MARTIN O’MALLEY, ) Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM AND ORDER

Plaintiff Angela Northcutt brings this action seeking judicial review of the Commissioner’s decision denying her application for disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. §§ 401. Section 205(g) of the Act, 42 U.S.C. §§ 405(g), provides for judicial review of a final decision of the Commissioner. Because the Commissioner’s final decision is supported by substantial evidence on the record as a whole, I will affirm the decision of the Commissioner. Procedural History Plaintiff was born in 1975 and protectively filed her application on August 31, 2021. (Tr. 10, 182-84.) She alleges she became disabled beginning August 16, 2021, because of degenerative disc disease, anxiety, arthritis, bipolar disorder, and borderline personality disorder. (Tr. 213.) Plaintiff’s application was initially denied on March 8, 2022 and upon reconsideration on April 20, 2022. (Tr. 119-22, 124-27.) After a telephonic

hearing before an ALJ on December 7, 2022, the ALJ issued a decision denying benefits on March 13, 2023. (Tr. 39-66, 10-22.) On December 6, 2023, the Appeals Council denied plaintiff’s request for review. (Tr. 1-6.) The ALJ’s

decision is now the final decision of the Commissioner. In this action for judicial review, plaintiff contends that the ALJ improperly evaluated opinion evidence and her subjective symptoms. She asks that I reverse the Commissioner’s final decision and remand the matter for further evaluation.

For the reasons that follow, I will affirm the Commissioner’s decision. Medical Records and Other Evidence Before the ALJ With respect to the medical records and other evidence of record, I adopt

plaintiff’s recitation of facts (ECF #8-1) only to the extent they are admitted by the Commissioner (ECF #9-1). I find the Commissioner’s clarifications of plaintiff’s statement of facts to be supported by the record, so I adopt his version of those facts (ECF #9-1). Additional specific facts will be discussed as needed to address

the parties’ arguments. Discussion A. Legal Standard

To be eligible for disability insurance benefits under the Social Security Act, 2 plaintiff must prove that she is disabled. Pearsall v. Massanari, 274 F.3d 1211, 1217 (8th Cir. 2001); Baker v. Secretary of Health & Human Servs., 955 F.2d 552,

555 (8th Cir. 1992). The Social Security Act defines disability as the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which

has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A). An individual will be declared disabled “only if [his] physical or mental impairment or impairments are of such severity that [she] is not only unable to do [her] previous work but cannot, considering [her]

age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy.” 42 U.S.C. § 423(d)(2)(A). To determine whether a claimant is disabled, the Commissioner engages in a

five-step evaluation process. See 20 C.F.R. § 404.1520; Bowen v. Yuckert, 482 U.S. 137, 140-42 (1987). At Step 1 of the process, the Commissioner begins by deciding whether the claimant is engaged in substantial gainful activity. If the claimant is working, disability benefits are denied. Next, at Step 2 the

Commissioner decides whether the claimant has a “severe” impairment or combination of impairments, meaning that which significantly limits her ability to do basic work activities. If the claimant’s impairment(s) is not severe, then she is

not disabled. At Step 3, the Commissioner then determines whether claimant’s 3 impairment(s) meets or equals one of the impairments listed in 20 C.F.R., Part 404, Subpart P, Appendix 1. If claimant’s impairment(s) is equivalent to one of the

listed impairments, she is conclusively disabled. At Step 4 of the process, the ALJ must assess the claimant’s RFC – that is, the most the claimant is able to do despite her physical and mental limitations, Martise v. Astrue, 641 F.3d 909, 923 (8th Cir.

2011) – and determine whether the claimant is able to perform her past relevant work. Goff v. Barnhart, 421 F.3d 785, 790 (8th Cir. 2005) (RFC assessment occurs at fourth step of process). If the claimant is unable to perform her past work, the Commissioner continues to Step 5 and determines whether the claimant

can perform other work as it exists in significant numbers in the national economy. If so, the claimant is found not disabled, and disability benefits are denied. The claimant bears the burden through Step 4 of the analysis. If she meets

this burden and shows that she is unable to perform her past relevant work, the burden shifts to the Commissioner at Step 5 to produce evidence demonstrating that the claimant has the RFC to perform other jobs in the national economy that exist in significant numbers and are consistent with her impairments and vocational

factors such as age, education, and work experience. Phillips v. Astrue, 671 F.3d 699, 702 (8th Cir. 2012). If the claimant has nonexertional limitations, the Commissioner may satisfy his burden at Step 5 through the testimony of a

vocational expert. King v. Astrue, 564 F.3d 978, 980 (8th Cir. 2009). 4 I must affirm the Commissioner’s decision if it is supported by substantial evidence on the record as a whole. 42 U.S.C. § 405(g); Richardson v. Perales, 402

U.S. 389, 401 (1971); Estes v. Barnhart, 275 F.3d 722, 724 (8th Cir. 2002). Substantial evidence is less than a preponderance but enough that a reasonable person would find it adequate to support the conclusion. Johnson v. Apfel, 240

F.3d 1145, 1147 (8th Cir. 2001). “[Substantial evidence] means – and means only – such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (internal quotation marks and citations omitted). Determining whether there is substantial

evidence requires scrutinizing analysis. Coleman v. Astrue, 498 F.3d 767, 770 (8th Cir. 2007). I must consider evidence that supports the Commissioner’s decision as well

as any evidence that fairly detracts from the decision. McNamara v. Astrue, 590 F.3d 607, 610 (8th Cir. 2010). If, after reviewing the entire record, it is possible to draw two inconsistent positions and the Commissioner has adopted one of those positions, I must affirm the Commissioner’s decision. Anderson v. Astrue, 696

F.3d 790, 793 (8th Cir. 2012).

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Related

Halverson v. Astrue
600 F.3d 922 (Eighth Circuit, 2010)
Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Martise v. Astrue
641 F.3d 909 (Eighth Circuit, 2011)
Buckner v. Astrue
646 F.3d 549 (Eighth Circuit, 2011)
Diana Phillips v. Michael J. Astrue
671 F.3d 699 (Eighth Circuit, 2012)

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