Pumphrey v. Saul

CourtDistrict Court, E.D. Missouri
DecidedFebruary 20, 2020
Docket4:18-cv-01925
StatusUnknown

This text of Pumphrey v. Saul (Pumphrey v. Saul) 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
Pumphrey v. Saul, (E.D. Mo. 2020).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

JEANETTE M. PUMPHREY, ) ) Plaintiff, ) ) vs. ) Case No. 4:18 CV 1925 ACL ) ANDREW M. SAUL, 1 ) Commissioner of Social Security ) Administration, ) ) Defendant. )

MEMORANDUM

Plaintiff Jeanette M. Pumphrey brings this action pursuant to 42 U.S.C. § 405(g), seeking judicial review of the Social Security Administration Commissioner’s denial of her application for Disability Insurance Benefits under Title II of the Social Security Act. An Administrative Law Judge (“ALJ”) found that Pumphrey was under a disability, but also concluded that a substance use disorder was a contributing factor material to the determination of disability because Pumphrey would not be disabled if she stopped the substance use. The ALJ therefore determined that Pumphrey was not disabled under the Social Security Act at any time from her alleged onset date through the date of her decision. This matter is pending before the undersigned United States Magistrate Judge, with consent of the parties, pursuant to 28 U.S.C. § 636(c). A summary of the entire record is presented in the parties’ briefs and is repeated here only to the extent necessary.

1After this case was filed, a new Commissioner of Social Security was confirmed. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Andrew M. Saul is substituted for Deputy Commissioner Nancy A. Berryhill as the defendant in this suit. Page 1 of 17 For the following reasons, the decision of the Commissioner will be affirmed. I. Procedural History Pumphrey filed her application for benefits on December 23, 2015, claiming that she became unable to work on August 30, 2011. (Tr. 156-63.) She subsequently amended her

alleged onset of disability date to October 24, 2016. (Tr. 38.) Her attorney explained that this was her “sober date but for one brief relapse after that with respect to alcohol issues.” Id. In her Disability Report, Pumphrey alleged disability due to epilepsy, seizures, blood clots in right lung, depression, and anxiety. (Tr. 203.) Pumphrey was 46 years of age on her alleged onset of disability date. (Tr. 19.) Her application was denied initially. (Tr. 78.) Pumphrey’s claim was denied by an ALJ on May 2, 2018. (Tr. 9-34.) On September 14, 2018, the Appeals Council denied Pumphrey’s claim for review. (Tr. 1-3.) Thus, the decision of the ALJ stands as the final decision of the Commissioner. See 20 C.F.R. §§ 404.981, 416.1481. In this action, Pumphrey argues that “the ALJ failed to properly evaluate RFC.” (Doc. 12 at p. 4.)

II. The ALJ’s Determination The ALJ first found that Pumphrey met the insured status requirements of the Social Security Act through December 31, 2016. (Tr. 14.) Pumphrey had not engaged in substantial gainful activity since her alleged onset date of October 24, 2016. Id. The ALJ next found that Pumphrey had the following severe impairments: history of seizure disorder; chronic alcoholic

pancreatitis; peripheral polyneuropathy; irritable bowel syndrome (“IBS”); major depressive disorder (“MDD”); alcohol dependence; anxiety disorder; bipolar disorder; and history of pulmonary embolism. (Tr. 14-15.) The ALJ found that Pumphrey did not have an impairment Page 2 of 17 or combination of impairments that met or medically equaled the severity of one of the listed impairments. (Tr. 15.) As to Pumphrey’s RFC, the ALJ stated: After careful consideration of the entire record, I find that, based on all of the impairments, including the substance use disorder, the claimant has the residual functional capacity to perform sedentary work as defined in 20 CFR 404.1567(a) except for the following nonexertional limitations that reduce the claimant’s capacity for sedentary work: can never climb ladders, ropes, or scaffolds: can no more than occasionally climb ramps or stairs; can no more than occasionally balance or stoop; must work around unprotected heights or moving mechanical parts; must never be required to operate a motor vehicle as a job duty; must never work in vibration; limited to simple, routine tasks and making simple work- related decisions; and must be able to be absent two days per month.

(Tr. 18.) The ALJ found that Pumphrey was unable to perform past relevant work, and that when considering her substance use disorder, there were no jobs that exist in significant numbers in the national economy that she could perform. (Tr. 19.) Next, the ALJ found that, if Pumphrey stopped her substance use, she would continue to have a severe combination of impairments. (Tr. 20.) The ALJ determined that Pumphrey would have the following RFC if she stopped the substance use: [T]he claimant would have the residual functional capacity to perform sedentary work as defined in 20 CFR 404.1567(a) except for the following nonexertional limitations that reduce the claimant’s capacity for sedentary work: can never climb ladders, ropes, or scaffolds: can no more than occasionally climb ramps or stairs; can no more than occasionally balance or stoop; must work around unprotected heights or moving mechanical parts; must never be required to operate a motor vehicle as a job duty; must never work in vibration; and limited to simple, routine tasks and making simple work-related decisions.

(Tr. 21.) The ALJ found that Pumphrey would continue to be unable to perform past relevant Page 3 of 17 work if she stopped the substance use, but there would be other jobs existing in significant numbers in the national economy that she could perform, such as addressor, document preparer, and charge account clerk. (Tr. 27.) The ALJ found that substance use was a contributing factor material to the determination

of disability because Pumphrey would not be disabled if she stopped the substance use. (Tr. 28.) As a result, she concluded that Pumphrey was not under a disability, as defined in the Social Security Act, at any time from the alleged onset date through the date of her decision. Id. The ALJ’s final decision reads as follows: Based on the application for a period of disability and disability insurance benefits protectively filed on December 23, 2015, the claimant is not disabled under sections 216(i) and 223(d) of the Social Security Act.

Id.

III. Applicable Law III.A. Standard of Review The decision of the Commissioner must be affirmed if it is supported by substantial evidence on the record as a whole. 42 U.S.C. § 405(g); Richardson v. Perales, 402 U.S. 389, 401 (1971); Estes v. Barnhart, 275 F.3d 722, 724 (8th Cir. 2002). Substantial evidence is less than a preponderance of the evidence, but enough that a reasonable person would find it adequate to support the conclusion. Johnson v. Apfel, 240 F.3d 1145, 1147 (8th Cir. 2001). This “substantial evidence test,” however, is “more than a mere search of the record for evidence supporting the Commissioner’s findings.” Coleman v.

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Richardson v. Perales
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Kluesner v. Astrue
607 F.3d 533 (Eighth Circuit, 2010)
Shirley Hutsell v. Larry G. Massanari, 1
259 F.3d 707 (Eighth Circuit, 2001)

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Pumphrey v. Saul, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pumphrey-v-saul-moed-2020.