Peloquin v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedFebruary 13, 2023
Docket4:21-cv-01153
StatusUnknown

This text of Peloquin v. Social Security Administration (Peloquin 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
Peloquin v. Social Security Administration, (E.D. Ark. 2023).

Opinion

EASTERN DIST ROG) UNITED STATES DISTRICT COURT FRR 13 □□ □□ EASTERN DISTRICT OF ARKANSAS ways CENTRAL DIVISION By:- - DEP CLI

STEPHANI PELOQUIN PLAINTIFF V. No. 4:21-CV-01153-KGB-JTR KILOLO KIJAKAZI, Acting Commissioner, Social Security Administration DEFENDANT RECOMMENDED DISPOSITION This Recommended Disposition (Recommendation) has been sent to United States District Judge Kristine G. Baker. 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 Baker 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 June 12, 2019, Stephani Peloquin (“Peloquin”’) filed a Title II application for disability insurance benefits. (Tr. at 13). In the application, she alleged disability beginning on February 15, 2016. /d. In a written decision dated January 13, 2021, an administrative law judge (“ALJ”) denied the application. (Tr. at 13-25). The Appeals Council denied Peloquin’s request for review on September 22, 2021. (Tr.

at 14). The ALJ’s decision now stands as the final decision of the Commissioner, and Peloquin has requested judicial review. For the reasons stated below, the Court concludes that the Commissioner’s

decision should be reversed and remanded. II. The Commissioner’s Decision At Step One of the required five-step analysis, the ALJ found that Peloquin had not engaged in substantial gainful activity during the period from her alleged onset date of February 15, 2016, through her date last insured of December 31, 2021.' (Tr. at 16). At Step Two, the ALJ determined that Peloquin’s fibromyalgia and bipolar disorder were severe impairments. (Tr. at 16). After finding that Peloquin’s impairments did not meet or equal a listed impairment (Tr. at 16-18),? the ALJ determined that Peloquin had the residual

! The ALJ followed the required five-step sequence 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; (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. §§ 404.1520(a)“(g). Peloquin acquired sufficient quarters of coverage to remain insured through December 31, 2021. (Tr. at 16). Therefore, the relevant time-period for determination of eligibility for benefits runs from February 15, 2016, through December 31, 2021. * See 20 C.F.R. Part 404, Subpt. P, Appendix 1.

4)

functional capacity (“RFC”)’ to perform work at the light exertional level, with

additional limitations to work involving no more than occasional interaction with

coworkers, and no direct interaction with the public. (Tr. at 18). At Step Four, the ALJ determined that Peloquin was unable to perform any

past relevant work. (Tr. at 23). At Step Five, the ALJ relied upon Vocational Expert (“VE”) testimony to find that, based on Peloquin’s age, education, work experience and RFC, jobs existed in significant numbers in the national economy that she could

perform, including positions such as small products assembler and housekeeper. (Tr. at 24-25). Thus, the ALJ concluded that Peloquin was not disabled. (Tr. at 25). 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

3.4 claimant's RFC represents the most she can do despite the combined effects of all of her credible limitations and must be based on all credible evidence. McCoy v. Astrue, 648 F.3d 605, 614 (8th Cir. 2011). In determining the claimant’s RFC, the ALJ has a duty to establish, by competent medical evidence, the physical and mental activity that the claimant can perform in a work setting, after giving appropriate consideration to all of their impairments. Ostronski v. Chater, 94 F.3d 413, 418 (8th Cir. 1996).

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: Our 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.’” Td. B. Peloquin’s Arguments on Appeal Peloquin contends that the evidence supporting the ALJ’s decision to deny benefits is less than substantial. She argues that the ALJ failed to properly evaluate the opinion of treating specialist Dr. Brian Bradford, which resulted in error in the

RFC determination.* Doc. 9. The Commissioner responds that the ALJ properly considered the opinions of Dr. Bradford. Doc. 10.

1. Background The record establishes Peloquin suffered from severe bipolar disorder with

mixed episodes and some psychotic features. (Tr. at 16, 310, 409, 524, 547). She had

a history of physical, sexual, psychological, and polysubstance abuse. (Tr. at 16, 546-553). Peloquin failed to attend her first administrative hearing. She did not answer

her phone, respond to her attorney’s messages, or provide any notice she would be

unable to attend. (Tr. at 32-36). At the second hearing, Peloquin testified she worked as a nurse until 2011. She stopped working due to mental health symptoms and lost her license in 2016 after a mental health related hospitalization. Peloquin saw a therapist every month for depression and bipolar disorder, and took prescription medications. She noted her medication helped a little. (Tr. at 19, 40-47). Peloquin was taking Topamax, trazodone, sertraline, and prazosin at the time, while Dr.

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