Parks v. Colvin

CourtDistrict Court, W.D. Missouri
DecidedJune 2, 2025
Docket2:24-cv-04083
StatusUnknown

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

Bluebook
Parks v. Colvin, (W.D. Mo. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI CENTRAL DIVISION

JOSHUA PARKS, ) ) Plaintiff, ) ) v. ) No. 2:24-CV-04083-DGK-SSA ) FRANK BISIGNANO, ) Commissioner of Social Security, ) ) Defendant. )

ORDER AFFIRMING THE COMMISSIONER’S DECISION

This case arises from the Commissioner of Social Security’s (“the Commissioner”) denial of Plaintiff Joshua Parks’ application for Supplemental Security Income (“SSI”) under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381–1385. The Administrative Law Judge (“ALJ”) found Plaintiff had several severe impairments, including psoriasis, psoriatic arthritis, diabetes mellitus, diabetic peripheral neuropathy, chronic obstructive pulmonary disease, bipolar disorder, generalized anxiety disorder, and alcohol abuse. The ALJ found that he retained the residual functional capacity (“RFC”) to perform light work with some additional restrictions. The ALJ then concluded that his RFC still allowed him to perform work as a retail marker, a routine clerk, an inserting machine operator, a document preparer, an addresser, and a tube operator. After carefully reviewing the record and the parties’ arguments, the Court finds the ALJ’s opinion is supported by substantial evidence on the record as a whole. The Commissioner’s decision is AFFIRMED. Procedural and Factual Background The complete facts and arguments are presented in the parties’ briefs and are repeated here only to the extent necessary. Plaintiff applied for SSI on May 27, 2021, alleging a disability onset date of April 30, 2021. The Commissioner denied the application at the initial claim level, and Plaintiff appealed the case to the ALJ. After holding a hearing, the ALJ found Plaintiff was not disabled. The Appeals Council denied Plaintiff’s request for review on February 16, 2024, leaving the ALJ’s decision as

the Commissioner’s final decision. Judicial review is now appropriate under 42 U.S.C. § 405(g). Standard of Review The Court’s review of the Commissioner’s decision to deny disability benefits is limited to determining whether the Commissioner’s findings are supported by substantial evidence on the record as a whole and whether the ALJ committed any legal errors. Igo v. Colvin, 839 F.3d 724, 728 (8th Cir. 2016). Substantial evidence is less than a preponderance but is enough evidence that a reasonable mind would find it sufficient to support the Commissioner’s decision. Id. In making this assessment, the Court considers evidence that detracts from the Commissioner’s decision, as well as evidence that supports it. Id. The Court must “defer heavily” to the Commissioner’s findings and conclusions. Wright v. Colvin, 789 F.3d 847, 852 (8th Cir. 2015); see Biestek v.

Berryhill, 139 S. Ct. 1148, 1157 (2019) (noting the substantial evidence standard of review “defers to the presiding ALJ, who has seen the hearing up close.”). The Court may reverse the Commissioner’s decision only if it falls outside of the available zone of choice; a decision is not outside this zone simply because the evidence also points to an alternate outcome. Buckner v. Astrue, 646 F.3d 549, 556 (8th Cir. 2011). Discussion The Commissioner follows a five-step sequential evaluation process1 to determine whether a claimant is disabled, that is, unable to engage in any substantial gainful activity by reason of a medically determinable impairment that has lasted or can be expected to last for a continuous

period of at least twelve months. 42 U.S.C. § 423(d)(1)(A). Here, Plaintiff argues that the ALJ erred at Step Four by failing to properly assess the opinion evidence from Jerry L. Cunningham, Psy.D. (“Dr. Cunningham”). More specifically, Plaintiff contends that the ALJ failed to explain how Dr. Cunningham’s opinion was unsupported by his own examination and how it was inconsistent with other record evidence. Defendant counters that substantial evidence supports the ALJ’s assessment of Dr. Cunningham’s opinion. In assessing the persuasiveness of medical opinions, an ALJ considers: “(1) whether they are supported by objective medical evidence, (2) whether they are consistent with other medical sources, (3) the relationship that the source has with the claimant, (4) the source’s specialization, and (5) any other relevant factors.” Bowers v. Kijakazi, 40 F.4th 872, 875 (8th Cir. 2022) (citing

20 C.F.R. § 404.1520c(c)). The most important factors in the analysis are supportability and consistency. Id. (citing 20 C.F.R. § 404.1520c(a)). The ALJ noted that he found Dr. Cunningham’s assessment of “marked” limitations in “social interaction and adaption” unpersuasive because “the evidence discussed above does not

1 “The five-step sequence involves determining whether (1) a claimant’s work activity, if any, amounts to substantial gainful activity; (2) his impairments, alone or combined, are medically severe; (3) his severe impairments meet or medically equal a listed impairment; (4) his residual functional capacity precludes his past relevant work; and (5) his residual functional capacity permits an adjustment to any other work. The evaluation process ends if a determination of disabled or not disabled can be made at any step.” Kemp ex rel. Kemp v. Colvin, 743 F.3d 630, 632 n.1 (8th Cir. 2014). Through Step Four of the analysis, Plaintiff bears the burden of showing that he is disabled. After the analysis reaches Step Five, the burden shifts to the Commissioner to show that there are other jobs in the economy that Plaintiff can perform. King v. Astrue, 564 F.3d 978, 979 n.2 (8th Cir. 2009). support the marked limitations.” R. 19. An extensive and lengthy evaluation of the record evidence pertaining to Plaintiff’s alleged limitations preceded this finding. R. at 10–18. The ALJ’s assessment of Dr. Cunningham’s opinion complies with the regulations and is supported by substantial evidence. On the support front, “the evidence discussed above” were

findings from Dr. Cunningham’s own evaluation that undermined his assessment of marked limitations. For example, despite assessing marked limitations in social interactions, Dr. Cunningham noted that Plaintiff got along well with supervisors and co-workers in his past job. R. at 18, 900. And although he found marked limitations in adaption, Dr. Cunningham noted that Plaintiff presented with a euthymic mood, made good eye contact, exhibited normal speech, denied anger control issues, exhibited no thought control issues, was dressed appropriately, and exhibited adequate hygiene. R. at 18, 899–901. On the consistency front, the ALJ did not use the exact words “consistency” in his assessment. But this is, at most, a deficiency in opinion writing because the record is clear that there were inconsistencies between Dr. Cunningham’s marked limitation findings and other

substantial, record evidence. See Grindley v. Kijakazi, 9 F.4th 622

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Related

Buckner v. Astrue
646 F.3d 549 (Eighth Circuit, 2011)
King v. Astrue
564 F.3d 978 (Eighth Circuit, 2009)
Vickie Kemp v. Carolyn Colvin
743 F.3d 630 (Eighth Circuit, 2014)
Kandi Cline v. Carolyn W. Colvin
771 F.3d 1098 (Eighth Circuit, 2014)
Karl Wright v. Carolyn W. Colvin
789 F.3d 847 (Eighth Circuit, 2015)
Curtis Igo v. Carolyn Colvin
839 F.3d 724 (Eighth Circuit, 2016)
Donald Fentress v. Carolyn W. Colvin
854 F.3d 1016 (Eighth Circuit, 2017)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Veronica Grindley v. Kilolo Kijakazi
9 F.4th 622 (Eighth Circuit, 2021)
Jason Bowers v. Kilolo Kijakazi
40 F.4th 872 (Eighth Circuit, 2022)

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Parks v. Colvin, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parks-v-colvin-mowd-2025.