Phillips v. Berryhill

CourtDistrict Court, W.D. Missouri
DecidedSeptember 14, 2018
Docket3:17-cv-05269
StatusUnknown

This text of Phillips v. Berryhill (Phillips v. Berryhill) 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
Phillips v. Berryhill, (W.D. Mo. 2018).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI SOUTHWESTERN DIVISION AIMEE PHILLIPS, ) ) Plaintiff, ) ) v. ) No. 17-05269-CV-SW-WJE-SSA ) NANCY A. BERRYHILL, ) Acting Commissioner of Social Security, ) ) Defendant. ) ORDER Plaintiff Aimee Phillips seeks judicial review1 of a final administrative decision of the Commissioner of Social Security (Commissioner) denying her disability insurance benefits (DIB) under Title II of the Social Security Act, 42 U.S.C. §§ 401 et seq., and Supplemental Security Income (SSI) under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381 et seq. Ms. Phillips contends that the Administrative Law Judge (ALJ) erred at the fifth step of a five-step sequential evaluation process in assessing disability claims by: (1) failing to properly evaluate the opinion of medical expert, Dorothy Kunstadt, M.D., that Plaintiff could reach only occasionally with her left hand; and (2) failing to present a proper hypothetical to the vocational expert that includes all of Plaintiff’s limitations. For the reasons that follow, the Commissioner’s decision will be reversed and remanded for further consideration and development of the record.

Background Ms. Phillips filed her applications for DIB and SSI on August 27, 2014, and August 29, 2014, respectively. (AR 109-10). Ms. Phillips alleges a disability onset date of August 22, 2013 due to depression, anxiety, migraines, chronic back pain, fibromyalgia, lymphedema, bursitis, knee pain, and insomnia. (AR 109-10, 197, 201). She was initially denied DIB and SSI on November 13, 2014. (AR 113-19). She then requested a hearing which was held on January 19, 2016. (AR 28-62). The ALJ issued a decision on August 30, 2016 denying Ms. Phillips’ claims. (AR 7-27).

1 With the consent of the parties, this case was assigned to the United States Magistrate Judge pursuant to the provisions of 28 U.S.C. § 636(c). Ms. Phillips sought review by the Appeals Council which was denied on October 10, 2017. (AR at 1-6, 208). Thus, the ALJ’s decision stands as the final decision of the Commissioner. On December 13, 2017, Ms. Phillips filed a complaint (Doc. 3) in this Court seeking review of the Commissioner’s decision. The case was assigned to the undersigned. Shortly thereafter, on January 5, 2018, all parties consented to the exercise of jurisdiction by the undersigned. (Doc. 4). The parties have fully briefed the issues (Docs. 8, 13, 14), and the case is now ripe for disposition.

Disability Determination and the Burden of Proof A claimant seeking disability insurance benefits has the burden of establishing he or she suffers from a disability as defined by the Social Security Act (SSA) in 42 U.S.C. § 423(d). Simmons v. Massanari, 264 F.3d 751, 754 (8th Cir. 2001); Roth v. Shalala, 45 F.3d 279, 282 (8th Cir. 1995). This requires demonstration of (1) a medically determinable impairment that has lasted or will likely last for a period of at least one year that (2) has rendered claimant unable to engage in any “substantial gainful activity” (3) because of the impairment. Id.; 42 U.S.C. § 423(d)(1)(A); see also McMillian v. Schweiker, 697 F.2d 215, 220 (8th Cir. 1983). Based on these criteria, the Social Security Administration has established a five-step, sequential evaluation process for appraising whether a claimant is disabled and benefit-eligible. 20 CFR §§ 404.1520(a) and 416.920(a); see also Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007). The Commissioner must evaluate: (1) whether the claimant is presently engaged in a substantial gainful activity; (2) whether the claimant has a severe impairment that significantly limits the claimant’s physical or mental ability to perform basic work activities; (3) whether the claimant has an impairment that meets or equals a presumptively disabling impairment listed in the regulations; (4) whether the claimant has the residual functional capacity to perform his or her past relevant work; and (5) if the claimant cannot perform the past work, the burden shifts to the Commissioner to prove that there are other jobs in the national economy that the claimant can perform.

Dixon v. Barnhart, 353 F.3d 602, 605 (8th Cir. 2003); Simmons, 264 F.3d at 754-55. At step one, the Commissioner must determine whether the claimant is engaged in substantial gainful activity (SGA). 20 CFR §§ 404.1520(a)(4)(i) and 416.920(a)(4)(i). “Substantial work activity” is work activity that involves doing significant physical or mental activities. 20 CFR § 404.1572(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). If the claimant is engaged in SGA, then the claimant is not disabled. 20 CFR §§ 404.1520(a)(4)(i) and 416.920(a)(4)(i). If the claimant is not engaging in SGA, the analysis proceeds to the second step. Next, at step two, the Commissioner must determine whether the claimant has a severe, medically-determinable impairment that significantly limits the claimant’s physical or mental ability to perform basic work activities. Dixon, 353 F.3d at 605. An impairment or combination of impairments is not severe when evidence—medical or otherwise—establishes one or more slight abnormalities that would have only a minimal effect on an individual’s ability to work. Kirby, 500 F.3d. at 707; 20 CFR §§ 404.1521 and 416.921. If the claimant does not have one or more severe, medically-determinable impairments, the claimant is not disabled under the SSA. If the claimant is found to be severely impaired, the analysis proceeds to the third step where the Commissioner must determine whether the claimant’s impairment(s) meet or medically equal the severity criteria listed in 20 CFR Part 404, Subpart P, Appendix 1. 20 CFR §§ 404.1520(d), 404.1525, 404.1526. If the impairment(s) meet the criteria and duration requirement, the claimant is disabled. Otherwise, the analysis proceeds to the next step.

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Related

Vossen v. Astrue
612 F.3d 1011 (Eighth Circuit, 2010)
Martise v. Astrue
641 F.3d 909 (Eighth Circuit, 2011)
Carroll F. Dixon v. Jo Anne B. Barnhart
353 F.3d 602 (Eighth Circuit, 2003)
Stephen R. Snead v. Jo Anne B. Barnhart
360 F.3d 834 (Eighth Circuit, 2004)
Kirby v. Astrue
500 F.3d 705 (Eighth Circuit, 2007)
Heino v. Astrue
578 F.3d 873 (Eighth Circuit, 2009)

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Bluebook (online)
Phillips v. Berryhill, Counsel Stack Legal Research, https://law.counselstack.com/opinion/phillips-v-berryhill-mowd-2018.