Rivera v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedSeptember 16, 2021
Docket3:20-cv-00291
StatusUnknown

This text of Rivera v. Social Security Administration (Rivera 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
Rivera v. Social Security Administration, (E.D. Ark. 2021).

Opinion

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

DESIREE L. RIVERA PLAINTIFF

v. 3:20-cv-00291-KGB-JJV

KILOLO KIJAKAZI, Acting Commissioner, Social Security Administration, DEFENDANT

PROPOSED FINDINGS AND RECOMMENDED DISPOSITION

INSTRUCTIONS

This recommended disposition has been submitted to United States District Judge Kristine G. Baker. The parties may file specific objections to these findings and recommendations and must provide the factual or legal basis for each objection. The objections must be filed with the Clerk no later than fourteen (14) days from the date of the findings and recommendations. A copy must be served on the opposing party. The district judge, even in the absence of objections, may reject these proposed findings and recommendations in whole or in part. RECOMMENDED DISPOSITION Desiree L. Rivera has appealed the final decision of the Commissioner of the Social Security Administration to deny her claim for disability insurance benefits and supplemental security income. The Administrative Law Judge (ALJ) concluded she had not been under a disability within the meaning of the Social Security Act, because jobs existed in significant numbers she could perform despite her impairments. (Tr. 283-287.) This review function is extremely limited. A 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 to analyze whether Plaintiff was denied benefits due to legal error. Long v. Chater, 108 F.3d 185, 187 (8th Cir. 1997); see also, 42 U.S.C. § 405(g). Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Richardson v. Perales, 402 U.S. 389, 401 (1971); Reynolds v. Chater, 82 F.3d 254, 257 (8th Cir. 1996). In assessing the substantiality of the evidence, courts must consider evidence that detracts from the Commissioner's decision as well as evidence that supports it; a court may not, however,

reverse the Commissioner's decision merely because substantial evidence would have supported an opposite decision. Woolf v. Shalala, 3 F.3d 1210, 1213 (8th Cir. 1993). The history of the administrative proceedings and the statement of facts relevant to this decision are contained in the respective briefs and are not in serious dispute. Therefore, they will not be repeated in this opinion except as necessary. After careful review of the pleadings and evidence in this case, I find the Commissioner’s decision is supported by substantial evidence and Plaintiff’s Complaint should be DISMISSED. Plaintiff is young. She was only thirty-three years old at the time of the administrative hearing. (Tr. 342.) She testified she went to the ninth grade in school but later earned her general

equivalency diploma. (Tr. 343.) She has past work as a scheduler and as a certified nurse’s assistant. (Tr. 295.) The ALJ1 found Ms. Rivera met the disability eligibility requirements to apply for disability insurance benefits. (Tr. 12.) She has “severe” impairments in the form of “seizure

1 The ALJ followed the required sequential analysis to determine: (1) whether the claimant was engaged in substantial gainful activity; (2) if not, whether the claimant had a severe impairment; (3) if so, whether the impairment (or combination of impairments) met or equaled a listed impairment; and (4) if not, whether the impairment (or combination of impairments) prevented the claimant from performing past relevant work; and (5) if so, whether the impairment (or combination of impairments) prevented the claimant from performing any other jobs available in significant numbers in the national economy. 20 C.F.R. §§ 416.920(a)-(g) and 404.1520(a)-(g). disorder, morbid obesity, lumbar degenerative disc disease (DDD), anxiety, depression, post- traumatic stress disorder (PTSD), and conversion disorder.” (Tr. 286.) The ALJ further found Ms. Rivera did not have an impairment or combination of impairments meeting or equaling an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1.2 (Tr. 286-288.) The ALJ determined Ms. Rivera had the residual functional capacity to perform a reduced

range of sedentary work given her physical and mental impairments. (Tr. 288.) The ALJ determined Ms. Rivera could no longer perform her past work, so he utilized the services of a vocational expert to determine if jobs existed that Plaintiff could perform despite her impairments. (Tr. 379-384.) Based in part on the testimony of the vocational expert, the ALJ determined she could perform the jobs of surveillance monitor and assembler - despite her limitations. (Tr. 296.) Accordingly, the ALJ determined Ms. Rivera was not disabled. (Id.) The Appeals Council considered additional evidence and then denied Plaintiff’s request for a review of the ALJ’s decision, making her decision the final decision of the Commissioner. (Tr. 1-279.) Plaintiff filed the instant Complaint initiating this appeal. (Doc. No. 2.)

In support of her Complaint, Ms. Rivera argues that the ALJ’s residual functional capacity (RFC) assessment was flawed in that, inter alia, it failed to fully account for Plaintiff’s seizure disorder. (Doc. No. 13 at 15-21.) Ms. Rivera clearly suffers from limitation from her seizure disorder. But given my limited review under the law, my careful review of the ALJ’s opinion, the extensive medical record, and the briefs from the respective parties, I find that the ALJ’s opinion is supported by substantial evidence. I find the Commissioner’s arguments persuasive - in particular that the “objective medical findings, Plaintiff’s daily living activities, and the non- examining state agency medical consultants’ assessments support the ALJ’s RFC assessment (Tr.

2 20 C.F.R. §§ 404.1520(d), 404.1525, and 404.1526. 386-429, 432-455, 1214, 1286-1287, 1297-1300, 1492)” (Doc. No. 14 at 8.) Understandably, Plaintiff believes the ALJ should have given more weight to the opinions of Kristi Ketz, Ph.D. (Doc. No. 13 at 18-19.) Dr. Ketz completed a Mental Status Examination, (Tr. 1304-1311), and concluded that Plaintiff had the decreased capacity to perform work related activities. (Tr. 1310.) The ALJ considered Dr. Ketz’s opinions and found them to be “not

supported by other medical evidence.” (Tr. 294.) He further found her opinions to be “. . . inconsistent with the claimants activities of daily living as noted [above]. . . [and] . . . inconsistent with the evidence from other medical and non-medical sources.” (Id.) While Dr. Ketz’s opinions certainly favor Plaintiff’s claim of disability, I find no error in the ALJ’s assessment here. Dr. Ketz’s evaluation is not so persuasive to overcome the other bases for which the ALJ concluded Plaintiff could perform sedentary work activities. The ALJ carefully considered the record and made a supported determination that Plaintiff was capable of performing a limited range of sedentary work.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Reutter Ex Rel. Reutter v. Barnhart
372 F.3d 946 (Eighth Circuit, 2004)
Robertson v. Sullivan
925 F.2d 1124 (Eighth Circuit, 1991)

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Bluebook (online)
Rivera v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rivera-v-social-security-administration-ared-2021.