Reaves v. Kijakazi

CourtDistrict Court, E.D. Missouri
DecidedSeptember 25, 2023
Docket4:22-cv-00839
StatusUnknown

This text of Reaves v. Kijakazi (Reaves v. Kijakazi) 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
Reaves v. Kijakazi, (E.D. Mo. 2023).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

MILDRED REAVES, ) ) Plaintiff, ) ) v. ) No. 4:22-CV-839 RLW ) KILOLO KIJAKAZI, ) Acting Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM AND ORDER

Plaintiff Mildred Reaves brings this action pursuant to 42 U.S.C. § 405(g) for judicial review of the Commissioner’s final decision denying her application for disability insurance benefits (DIB) under Title II of the Social Security Act, 42 U.S.C. §§ 401, et seq. and for supplemental security income (SSI) under Title XVI of the Act, 42 U.S.C. §§ 1381, et seq. For the reasons that follow, the decision of the Commissioner is affirmed. I. Procedural History On November 8, 2018, Plaintiff protectively filed her application for DIB under Title II. (Tr. 247-49). Plaintiff alleged she had been unable to work since October 1, 2014, due to a dislocated right shoulder; fractured right humerus, ulnar neuritis, anxiety, ADHD, and trigger finger on right hand. (Tr. 93, 247-49).1 Plaintiff’s application was denied on initial consideration, and she requested a hearing before an Administrative Law Judge (“ALJ”). Plaintiff and counsel appeared for a hearing on June 11, 2021. (Tr. 51-83). Plaintiff testified concerning her disability, daily activities, functional limitations, and past work. Id. The ALJ also received testimony from

1On January 5, 2019, Plaintiff changed her alleged disability onset date to November 30, 2016. (Tr. 245). On March 25, 2021, Plaintiff again amended her onset date of disability to May 22, 2018. (Tr. 279). vocational expert (“VE”) James Israel. Id. On July 14, 2021, the ALJ issued an unfavorable decision finding Plaintiff not disabled. (Tr. 14-29). Plaintiff filed a request for review of the ALJ’s decision with the Appeals Council. On June 10, 2022, the Appeals Council denied Plaintiff’s request for review. (Tr. 1). Plaintiff has exhausted her administrative remedies, and the ALJ’s decision stands as the final decision of the Commissioner subject to judicial review. See 42 U.S.C. §§ 405(g), 1383(c)(3). In this action for judicial review, Plaintiff claims the ALJ’s decision is not supported by

substantial evidence in the record as a whole. Specifically, Plaintiff argues the ALJ’s findings regarding Plaintiff’s residual functional capacity (“RFC”) are not supported by the medical evidence in that there were no expert medical opinions the ALJ found persuasive, and the ALJ improperly drew her own inferences about Plaintiff’s functional ability from the medical records. Plaintiff further argues that the ALJ did not properly evaluative Plaintiff’s subjective complaints of pain. Plaintiff contends the ALJ did not consider her inability to pay for treatment, and in evaluating her complaints of pain, misconstrued evidence of Plaintiff’s reported activities and engagement with medical treatment. Plaintiff requests that the Commissioner’s decision be reversed and the matter remanded for an award of benefits or for further evaluation. With regard to Plaintiff’s testimony, medical records, and work history, the Court accepts

the facts as presented in the parties’ respective statements of facts and responses. The Court will discuss specific facts relevant to the parties’ arguments as needed in the discussion below. II. Legal Standard To be eligible for DIB under the Social Security Act, plaintiff must prove she is disabled. Pearsall v. Massanari, 274 F.3d 1211, 1217 (8th Cir. 2001); Baker v. Sec'y of Health & Hum. Servs., 955 F.2d 552, 555 (8th Cir. 1992). The Social Security Act defines 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)(1)(A), 1382c(a)(3)(A). An individual will be declared disabled “only if his [or her] physical or mental impairment or impairments are of such severity that he [or she] is not only unable to do his [or her] previous work but cannot, considering his [or her] age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy.” 42 U.S.C. §§ 423(d)(2)(A), 1382c(a)(3)(B).

To determine whether a claimant is disabled, the Commissioner engages in a five-step evaluation process. See 20 C.F.R. §§ 404.1520, 416.920; Bowen v. Yuckert, 482 U.S. 137, 140- 42 (1987). The Commissioner begins by deciding whether the claimant is engaged in substantial gainful activity. If the claimant is working, disability benefits are denied. Second, the Commissioner decides whether the claimant has a “severe” impairment or combination of impairments, meaning that which significantly limits his or her ability to do basic work activities. If the claimant’s impairment is not severe, then he or she is not disabled. Third, if the claimant has a severe impairment, the Commissioner considers the impairment’s medical severity. If the impairment meets or equals one of the presumptively disabling impairments listed in 20 C.F.R., Part 404, Subpart P, Appendix 1, the claimant is considered disabled, regardless of age, education,

and work experience. 20 C.F.R. §§ 416.920(a)(4)(iii), (d). At the fourth step, if the claimant’s impairment is severe but does not meet or equal one of the presumptively disabling impairments, the Commissioner assesses whether the claimant retains the RFC to perform his or her past relevant work. 20 C.F.R. §§ 416.920(a)(4)(iv), 416.945(a)(5)(i). An RFC is “defined as the most a claimant can still do despite his or her physical or mental limitations.” Martise v. Astrue, 641 F.3d 909, 923 (8th Cir. 2011); see also 20 C.F.R. § 416.945(a)(1). Ultimately, the claimant is responsible for providing evidence relating to his or her RFC, and the Commissioner is responsible for developing the claimant’s “complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help [the claimant] get medical reports from [the claimant’s] own medical sources.” 20 C.F.R. § 416.945(a)(3). If, upon the findings of the ALJ, it is determined the claimant retains the RFC to perform past relevant work, he or she is not disabled. 20 C.F.R. § 416.920(a)(4)(iv).

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Related

Halverson v. Astrue
600 F.3d 922 (Eighth Circuit, 2010)
Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Martise v. Astrue
641 F.3d 909 (Eighth Circuit, 2011)
Brock v. Astrue
674 F.3d 1062 (Eighth Circuit, 2012)
Stephen R. Snead v. Jo Anne B. Barnhart
360 F.3d 834 (Eighth Circuit, 2004)

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Reaves v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/reaves-v-kijakazi-moed-2023.