Potter v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedAugust 25, 2022
Docket4:21-cv-00945
StatusUnknown

This text of Potter v. Social Security Administration (Potter 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
Potter v. Social Security Administration, (E.D. Ark. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

ERIC E. POTTER PLAINTIFF

V. No. 4:21-CV-945-LPR-JTR

KILOLO KIJAKAZI, Acting Commissioner, Social Security Administration DEFENDANT

RECOMMENDED DISPOSITION

This Recommended Disposition (“Recommendation”) has been sent to United States District Judge Lee P. Rudofsky. 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 Rudofsky may 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 July 3, 2018, Eric E. Potter (“Potter”) filed a Title II application for a period of disability and disability insurance benefits. (Tr. at 10). In the application, he alleged disability beginning on November 4, 2016. Id. In a written decision dated February 2, 2021, an administrative law judge (“ALJ”) denied the application. (Tr. at 17). The Appeals Council denied Potter’s request for review on August 27, 2021. (Tr. at 1–3). Thus, the ALJ’s decision now stands as the final decision of the

Commissioner. Potter has requested judicial review. For the reasons stated below, this Court should reverse the final decision of the Commissioner and remand for further review.

II. The ALJ’s Decision At Step One of the required five-step analysis,1 the ALJ found that Potter had not engaged in substantial gainful activity since November 4, 2016. (Tr. at 12). At Step Two, the ALJ determined that Potter has the following medically determinable

impairments: (1) diabetes mellitus with neuropathy; (2) osteoarthritis of the right knee status post-surgery; (3) bilateral pes valgus; (4) posterior tarsal tendinitis; (5) sinus tarsitis; and (6) hypertension. Id. However, after considering these

impairments individually and in combination, the ALJ found that there were not “severe” impairments.2 Id. Thus, based on those Step Two findings, the ALJ concluded that Potter was not disabled. Id.

1 20 C.F.R. §§ 404.1520(a)–(g), 416.920(a)–(g). 2 A “severe” impairment significantly limits the claimant’s physical or mental ability to perform basic work-related activities for 12 consecutive months. 20 CFR §§ 404.1520(c), 404.1509. “An impairment is not severe if it amounts only to a slight abnormality that would not significantly limit the claimant's physical or mental ability to do basic work activities.” Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007) (citing Bowen v. Yuckert, 482 U.S. 137, 153, 158 (1987)). 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

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, in the context of administrative decisions, the Supreme Court has explained that: “[W]hatever 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.’” Id. B. Potter’s Arguments on Appeal Potter contends that the evidence supporting the ALJ’s Step Two decision to

deny benefits is less than substantial. He argues that: (1) the ALJ erred in finding that Potter’s impairments were non-severe; (2) the ALJ failed to fully develop the record; and (3) the ALJ failed to properly evaluate Potter’s subjective complaints.

In August 2016, Potter, who is obese, was diagnosed with Type 2 diabetes, and his provider noted that is blood sugars measured in the 200’s. (Tr. at 269–271). In early 2018, Karl P. Sandberg, M.D., of Chambers Memorial Clinic, prescribed an insulin regimen for Potter, as well as Glipizide to manage his diabetes. (Tr. at 254–

256). Potter did not take his insulin regularly, and consequently, his blood sugars surged to the 300’s. (Tr. at 308–310, 356). William Berry, M.D., also treated Potter at the Chambers Clinic; he diagnosed back pain and knee pain and prescribed

Naproxen. (Tr. at 318). Dr. Berry also tracked Potter’s type 2 diabetes. In May 2018, Potter reported to Dr. Sandberg that he had chronic knee pain even after ACL repair. (Tr. at 254–256). Potter also complained of blurry vision and he sought a diabetic eye examination. (Tr. at 322–326).

Potter suffered from diabetic neuropathy in his feet and sought treatment from Veta Ferdowsian, D.P.M., at the Foot and Ankle Specialty Clinic. On September 2019, Potter told Dr. Ferdowsian that his blood sugars were above 300 and he had

pain in his feet with weightbearing. (Tr. at 307–310). Dr. Ferdowsian gave Potter heat molded insoles and a leg brace. Id. When Potter returned to Dr. Ferdowsian in October 2019, his blood sugars were again high. (Tr. at 310).

Potter said that his impairments made prolonged daily activities difficult. (Tr. at 196). In September 2018, Garry Stewart M.D., performed a consultative

examination on behalf of the Administration. He noted as impairments Type 2 diabetes, hypertension, osteoarthritis of the right knee, bilateral carpal tunnel syndrome, and left shoulder fracture. (Tr. at 283–288). Potter complained of headache and blurred vision. Potter also complained of nausea, vomiting, and

diarrhea. Id. It does not appear that Dr. Stewart obtained a blood sugar reading. Dr. Stewart concluded that Potter had no functional limitations. Id. Dr. Berry filled out a medical source statement in November 2019. (Tr. at

312-315). He found that Potter could stand or walk for a total of 3 hours and sit for a total of 4, and that he could lift and carry less than 10 pounds. Id. This means Dr. Berry did not think Potter could perform even sedentary work.3 The Disability Determination Services medical experts reviewed the records

and found that Potter’s impairments were non-severe. (Tr. at 70, 79). The ALJ adopted these findings.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Jean Dozier v. Margaret M. Heckler
754 F.2d 274 (Eighth Circuit, 1985)
Johnnie D. Freeman v. Kenneth S. Apfel
208 F.3d 687 (Eighth Circuit, 2000)
Kirby v. Astrue
500 F.3d 705 (Eighth Circuit, 2007)
Charles Miller v. Carolyn W. Colvin
784 F.3d 472 (Eighth Circuit, 2015)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)

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Potter v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/potter-v-social-security-administration-ared-2022.