Randle v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedMarch 9, 2022
Docket4:21-cv-00256
StatusUnknown

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

Opinion

IN THE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

LAKEISHA RANDLE PLAINTIFF

V. CASE NO. 4:21-CV-00256-KGB-ERE

COMMISSIONER of 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. Objections 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 January 5, 2018, Lakeisha Randle applied for disability benefits, alleging disability beginning September 28, 2017. (Tr. at 15). Her claims were denied both initially and upon reconsideration. Id. After conducting a hearing on April 29, 2019, an Administrative Law Judge (“ALJ”) denied Ms. Randle’s application on June 7, 2019. (Tr. at 31). Following the ALJ’s order, Ms. Randle sought review from the Appeals Council, which denied her request for review. (Tr. at 1). Ms. Randle seeks

judicial review of the ALJ’s decision, which now stands as the Commissioner’s final decision. For the reasons stated below, the Court should affirm the decision of the

Commissioner. II. THE COMMISSIONER’S DECISION The ALJ found that Ms. Randle had not engaged in substantial gainful activity since the alleged onset date of September 28, 2017. (Tr. at 18). At Step Two, the

ALJ found that Ms. Randle had the following severe impairments: residuals from a left Schatzker VI tibial plateau fracture with associated posterior knee dislocation status post multiple surgical procedures and anxiety. Id.

After finding Ms. Randle’s impairments did not meet or equal a listed impairment (Tr. at 18), the ALJ determined that she had the residual functional capacity (“RFC”) to perform work at the sedentary exertional level, except that she could: (1) sit six to eight hours during an eight-hour workday, one to two hours

without interruption; (2) stand one to two hours during an eight-hour workday, no more than 15 to 30 minutes at a time; (3) occasionally climb, stoop, crouch, kneel, and crawl; (4) perform unskilled/rote activity in that she would understand, follow,

and remember concrete instructions; and (5) have superficial contact with supervisors, co-workers, and the public meaning that she could meet, greet, make change, and give simple instructions and directions. (Tr. at 20).

Relying on the testimony of a Vocational Expert (“VE”), the ALJ found that Ms. Randle was unable to perform her past relevant work as a machine operator, but that Ms. Randle’s RFC would allow her to perform jobs that exist in significant

numbers in the national economy, including machine tender and inspector. (Tr. at 29-30). The ALJ concluded that Ms. Randle was not disabled. (Tr. at 31). III. DISCUSSION A. Standard of Review

In this appeal, the Court must review the Commissioner’s decision for legal error and determine whether the decision is supported by substantial evidence on the record as a whole. Brown v. Colvin, 825 F.3d 936, 939 (8th Cir. 2016) (citing

Halverson v. Astrue, 600 F.3d 922, 929 (8th Cir. 2010)). “Substantial evidence” in this context means “enough that a reasonable mind would find [the evidence] adequate to support the ALJ’s decision.” Slusser v. Astrue, 557 F.3d 923, 925 (8th Cir. 2009) (citation omitted). In making this determination, the Court must consider

not only evidence that supports the Commissioner’s decision, but also evidence that supports a contrary outcome. Milam v. Colvin, 794 F.3d 978, 983 (8th Cir. 2015). The Court will not reverse the Commissioner’s decision, however, “merely because substantial evidence exists for the opposite decision.” Long v. Chater, 108 F.3d 185, 187 (8th Cir. 1997) (citation omitted).

B. Ms. Randle’s Arguments on Appeal Ms. Randle, appearing pro se, argues that the ALJ’s decision is not supported by substantial evidence. She argues that the ALJ erred in evaluating her subjective

complaints and that her RFC does not capture the concrete consequences of her functional limitations. After reviewing the record as a whole, the Court concludes that the ALJ did not err in denying benefits. A claimant bears the burden of proving her RFC, which represents the most

she can do despite the combined effects of her credible limitations. Pearsall v. Massanari, 274 F.3d 1211, 1217 (8th Cir. 2001). “It is the ALJ’s responsibility to determine a claimant’s RFC based on all relevant evidence, including medical

records, observations of treating physicians and others, and claimant’s own descriptions of [her] limitations.” Id. Part of the RFC determination requires assessing a claimant’s credibility regarding her subjective complaints. A claimant’s credibility is primarily for the ALJ, not the courts, to decide. Id. at 1218.

In this case, the ALJ properly evaluated Ms. Randle’s subjective complaints by considering her work history, the objective medical evidence, and other relevant evidence, including: (1) her daily activities; (2) the duration, frequency, and intensity

of her pain and other symptoms; (3) precipitating and aggravating factors; (4) the dosage, effectiveness, and side effects of medication; and (5) her functional restrictions. See Schwandt v. Berryhill, 926 F.3d 1004, 1012 (8th Cir. 2019); see also

20 C.F.R. §§ 404.1529(c), 416.929(c). After reviewing the evidence, the ALJ determined Ms. Randle’s complaints were not entirely credible. Ms. Randle’s course of treatment and medications support the ALJ’s finding.

In September 2017, she was injured in a scooter accident, resulting in tibial fractures with dislocation of her left knee. (Tr. at 605). Following surgery, she was non-weight bearing to her left lower extremity and was in a knee brace. (Tr. at 321). Two months later, after a round of physical therapy, the pain and swelling in her leg was much

improved and she was “[t]aking minimal pain medicine, really only to sleep.” (Tr. at 634). Range of motion in her knee, however, was limited. Id. In January 2018, she was weightbearing as tolerated and did not use assistive devices when ambulating.

(Tr. at 631). She was not taking any prescription or over-the-counter pain medicine. Id. To improve her knee range of motion, she underwent a knee manipulation under anesthesia and left knee steroid injection. (Tr. at 315). She continued physical therapy, and by March 2018 her range of motion had improved, though she did report

some pain with weightbearing, especially after therapy sessions. (Tr. at 452-53). In April 2018, she underwent a left knee arthroscopy with lysis of adhesions to address residual pain and stiffness in her knee. (Tr. at 589). Two days later, Ms. Randle was

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Related

Halverson v. Astrue
600 F.3d 922 (Eighth Circuit, 2010)
Perkins v. Astrue
648 F.3d 892 (Eighth Circuit, 2011)
Slusser v. Astrue
557 F.3d 923 (Eighth Circuit, 2009)
Moore v. Astrue
572 F.3d 520 (Eighth Circuit, 2009)
Medhaug v. Astrue
578 F.3d 805 (Eighth Circuit, 2009)
Tracy Milam v. Carolyn W. Colvin
794 F.3d 978 (Eighth Circuit, 2015)
Timothy Brown v. Carolyn W. Colvin
825 F.3d 936 (Eighth Circuit, 2016)
Charles Bryant v. Nancy A. Berryhill
861 F.3d 779 (Eighth Circuit, 2017)
Jessie Nash v. Commissioner, Social Security
907 F.3d 1086 (Eighth Circuit, 2018)

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