Parker v. O'Malley

CourtDistrict Court, E.D. Missouri
DecidedMarch 4, 2025
Docket1:24-cv-00008
StatusUnknown

This text of Parker v. O'Malley (Parker 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
Parker v. O'Malley, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEASTERN DIVISION

KEITH T. PARKER, ) ) Plaintiff, ) ) v. ) No. 1:24 CV 8 RWS ) LELAND DUDEK, ) Acting Commissioner of Social ) Security, ) ) Defendant. )

MEMORANDUM AND ORDER

Keith Parker brings this action pursuant to 42 U.S.C. §§ 405(g) seeking judicial review of the Commissioner’s decision denying his application for disability benefits under the Social Security Disability Insurance Program (SSDI), Title II of the Social Security Act, 42 U.S.C. §§ 401-434 and for benefits under the Supplemental Security Income Program (SSI), Title XVI of the Social Security Act, 42 U.S.C. §§ 1381-1385. For the reasons set forth below, I will affirm the decision of the Commissioner. Procedural History Plaintiff Keith Parker was born on June 5, 1971. (Tr. 196) He is currently 53 years old. Parker earned his GED in October 1989. (Tr. 229) In the past several years before he applied for disability benefits Parker worked as a semi- truck driver and in a factory sawing and stacking lumber. (Tr. 245-248) Parker

had employment earnings of $23,438.90 in 2020 and $10,294.39 in 2021. (Tr. 205) The last time he had gainful employment was on June 4, 2021. (Tr. 12.) Parker protectively filed a Title II application for a period of disability and

disability insurance benefits and a Title XVI application for supplemental security income on April 26, 2021. (Tr. 193-195) He initially alleged his disability began on April 10, 2021 (Tr. 193) but amended the date of disability to June 4, 2021. (Tr. 226) Parker’s applications were initially denied on July 8, 2021. (Tr. 63-64)

The applications were denied again upon reconsideration on October 14, 2021. (Tr. 77-78) On October 22, 2021, Parker filed a request for a hearing before an Administrative Law Judge (ALJ). (Tr. 119) The ALJ held an online video

hearing on February 7, 2023. (Tr. 26-62) In his Disability Report, completed on May 3, 2021, Parker asserted that he was unable to work based on severe back pain with 2 herniated / compressed disks, hypertension, and diabetes. (Tr. 228) At the hearing before the ALJ Parker’s counsel stated that Parker’s impairments are

primarily based on his spinal issues. (Tr. 35) Parker testified that his back issues keep him from working. He testified he did not have any feeling in his left leg or foot; he cannot sit or stand for very long; and he cannot walk very far without

assistance. (Tr. 48) On February 17, 2023, the ALJ issued a decision finding that 2 Parker was not disabled. (Tr. 20) On May 23, 2023, the Appeals Council denied plaintiff’s request for review. (Tr. 1) The ALJ’s decision is now the final decision

of the Commissioner. 42 U.S.C. §§ 405(g). In this action for judicial review, Parker contends that the ALJ failed to develop the record fully and fairly and that the ALJ failed to properly evaluate the

credibility of Parker’s subjective complaints. (ECF # 17) Parker requests that I reverse the Commissioner’s final decision and remand this matter for further evaluation. For the reasons that follow, I will deny Parker’s request to remand this matter for further proceedings.

Medical Records and Other Evidence Before the ALJ With respect to the medical records and other evidence of record, I adopt Parker’s statement of material facts (ECF # 18) and the Commissioner’s additional

material facts (ECF # 21). Additional 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, a plaintiff must prove that he 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 3 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 he is

not only unable to do his previous work but cannot, considering his 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). The Commissioner begins by deciding whether the claimant is engaged in substantial gainful activity (SGA).1 If not, the disability

analysis proceeds to the second step. In this step the Commissioner decides whether the claimant has a “severe” impairment or combination of impairments, meaning that which significantly limits his ability to do basic work activities. If the claimant’s impairment(s) is not severe, then he is not disabled and the analysis

1 “Substantial gainful activity (SGA) is defined as work activity that is both substantial and gainful. ‘Substantial work activity’ is work activity that involves doing significant physical or mental activities (20 CFR 404.1572(a) and 416.972(a)). ‘Gainful work activity’ is work that is usually done for pay or profit, whether or not a profit is realized (20 CFR 404.1572(b) and 416.972(b)). Generally, if an individual has earnings from employment or self- employment above a specific level set out in the regulations, it is presumed that he has demonstrated the ability to engage in SGA (20 CFR 404.1574, 404.1575, 416.974, and 416.975). If an individual engages in SGA, he is not disabled regardless of how severe his physical or mental impairments are and regardless of his age, education, and work experience.” (Tr. 12.) 4 ends. If the claimant has a severe impairment the Commissioner then proceeds to the third step and determines whether claimant’s 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, he is conclusively disabled. If the impairment is not equivalent to a listed impairment,

then the Commissioner proceeds to the fourth step to determine whether the claimant can perform his past relevant work.2 If so, the claimant is not disabled.

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Parker v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parker-v-omalley-moed-2025.