Phillips v. Dudek

CourtDistrict Court, E.D. Missouri
DecidedMarch 28, 2025
Docket1:23-cv-00175
StatusUnknown

This text of Phillips v. Dudek (Phillips v. Dudek) 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
Phillips v. Dudek, (E.D. Mo. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEASTERN DIVISION

WILLIAM J. PHILLIPS, ) ) Plaintiff, ) ) vs. ) No. 1:23-cv-00175-MTS ) LELAND DUDEK, Acting Commissioner of ) the Social Security Administration,1 ) ) Defendant. )

MEMORANDUM AND ORDER This matter is before the Court for review of a partially adverse ruling by Defendant, the Acting Commissioner of the Social Security Administration. For the following reasons, the Court will reverse and remand the matter to the Acting Commissioner.2 I. Background On June 02, 2017, William Phillips (“Plaintiff”) applied for Disability Insurance Benefits (“DIB”) under Title II of the Social Security Act (the “Act”), 42 U.S.C. §§ 401–434 and Supplemental Security Income (“SSI”) under Title XVI of the Act, 42 U.S.C. §§ 1381–1385. (Tr. 300–316). Plaintiff alleges disability due to chronic obstructive pulmonary disease (“COPD”), depression, anxiety, post-traumatic stress disorder (“PTSD”), and high blood pressure, with an alleged onset date of January 01, 2014. (Tr. 333, 337). After the Commissioner initially denied Plaintiff’s applications, Plaintiff requested a hearing before an Administrative Law Judge (“ALJ”).

1 Leland Dudek is now the Acting Commissioner of the Social Security Administration. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Dudek is substituted as the proper defendant.

2 Section 405(g) of Title 42 provides for judicial review of the SSA Commissioner’s “final decision.” After the ALJ concluded Plaintiff was not disabled under the Act prior to April 23, 2020, (Tr. 720), the Appeals Council did not assume jurisdiction in this matter; thus, the ALJ’s decision stands as the Commissioner’s final decision. On August 21, 2019, following a hearing, ALJ Mannes issued his decision finding that Plaintiff was not disabled as defined in the Act. (Tr. 18). Plaintiff then requested review of the ALJ’s decision by the Appeals Council, which denied review on August 27, 2019. (Tr. 35–37). Plaintiff appealed to the U.S. District Court for the Eastern District of Oklahoma, and a

magistrate judge issued a report and recommendation (“R&R”) on February 24, 2022. (Tr. 810–20); Phillips v. Kijakazi, 6:20-cv-00288-SPS, 2022 WL 794708 (E.D. Okla. Feb. 24, 2022). In the R&R, the magistrate judge found that the ALJ had failed to properly evaluate two medical opinions of state agency psychological consultant, Dr. Theresa Horton. (Tr. 818–19). The magistrate judge stated that, although the ALJ had summarized Dr. Horton’s June 10, 2014, and September 6, 2017, opinions and stated that they were complementary and partially persuasive, the ALJ failed to specifically discuss the supportability and consistency factors in explaining why he found the opinions partially persuasive, as required under 20 C.F.R. §§ 416.920c(b). (Tr. 818). The magistrate judge continued: [T]he ALJ purported to adopt both of [Dr. Horton’s opinions] by finding them partially persuasive, but this ignores the fact that they were different in kind and degree of impairment noted for the claimant. Furthermore, the ALJ provided no clarity as to how they were partially persuasive and yet he nevertheless did not adopt all the limitations proposed by even the most recent one. It was error for the ALJ to “pick and choose” his way through the evidence in this record in order to avoid finding the claimant disabled.

(Tr. 819). The magistrate judge instructed that if the ALJ’s analysis on remand “result[ed] in any adjustment to the claimant’s RFC, the ALJ should then re-determine what work, if any, the claimant can perform and ultimately whether he is disabled.” Id. Thus, the magistrate judge recommended reversing the Commissioner’s decision and remanding the case for further proceedings. (Tr. 820). The magistrate judge also proposed finding that the ALJ did not apply the correct legal standards, and that the Commissioner’s decision was therefore not supported by substantial evidence. Id. On March 14, 2022, the district court summarily adopted the R&R, including the proposed finding, reversed the Commissioner’s decision, and remanded the case for further analysis. (Tr. 809); Phillips v. Kijakazi, 6:20-cv-00288-RAW, 2022 WL 791649 (E.D. Okla. Mar. 14, 2022).

On remand, following another hearing, ALJ Neel, issued a partially favorable decision on May 10, 2023, finding that “the claimant was not disabled prior to April 23, 2020, but became disabled on that date and has continued to be disabled through the date of this decision.” (Tr. 702–720). The ALJ then determined that claimant was not under a disability within the meaning of the Act at any time between the alleged onset date of January 01, 2014, through the date last insured of March 31, 2019. (Tr. 720). Plaintiff now appeals the unfavorable portion of the May 10, 2023, decision. II. Standard of Review and Legal Framework To be eligible for disability benefits, Plaintiff must prove that he is disabled under the Act. Baker v. Sec’y of Health & Hum. Servs., 955 F.2d 552, 555 (8th Cir. 1992). The Act defines a

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), 1382c(a)(3)(A). A claimant will be found to have a disability “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 also unable to “engage in any other kind of substantial gainful work which exists in the national economy.” Id. at §§ 423(d)(2)(A), 1382c(a)(3)(B). The Social Security Administration has established a five-step sequential process for determining whether a claimant is disabled. 20 C.F.R. § 404.1520(a). Steps 1–3 require the claimant to prove: (1) he is not currently engaged in substantial gainful activity; (2) he suffers from a severe impairment; and (3) his disability meets or equals a listed impairment. Id. at §§ 404.1520(a)–(d). If the claimant does not suffer from a listed impairment or its equivalent, the analysis proceeds to Steps 4 and 5. Id. at § 416.920(e). At this point, the ALJ assesses the

claimant’s residual functioning capacity (“RFC”), “which is the most a claimant can do despite h[is] limitations.” Moore v. Astrue, 572 F.3d 520, 523 (8th Cir. 2009); 20 C.F.R. § 404.1545. The U.S. Court of Appeals for the Eighth Circuit has noted that the ALJ must determine a claimant’s RFC based on all relevant, credible evidence in the record, including medical records, the observations of treating physicians and others, and the claimant’s own description of his symptoms and limitations. Goff v. Barnhart, 421 F.3d 785, 793 (8th Cir. 2005).

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Phillips v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/phillips-v-dudek-moed-2025.