Robert Westan Parratt v. Social Security Administration

CourtDistrict Court, W.D. Missouri
DecidedMarch 25, 2026
Docket4:24-cv-00723
StatusUnknown

This text of Robert Westan Parratt v. Social Security Administration (Robert Westan Parratt v. Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, W.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Robert Westan Parratt v. Social Security Administration, (W.D. Mo. 2026).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF MISSOURI WESTERN DIVISION ROBERT WESTAN PARRATT, ) ) Plaintiff, ) ) v. ) Case No. 4:24-cv-00723-RK ) SOCIAL SECURITY ) ADMINISTRATION, ) ) Defendant. ) ORDER Before the Court is Plaintiff Robert Westan Parratt’s appeal brought under 42 U.S.C. § 405(g), seeking review of the Commissioner of the Social Security Administration’s denial of disability benefits as rendered in a decision by an Administrative Law Judge (“ALJ”). After careful consideration and for the reasons explained below, because the ALJ failed to sufficiently explain why the Plaintiff’s mild mental limitation of interacting with others was not incorporated into the RFC to allow the Court to meaningfully consider whether the ALJ’s decision is supported by substantial evidence, the Court ORDERS that the ALJ’s decision is AFFIRMED in part and REVERSED in part. This case is REMANDED for further proceedings consistent with this Order. Background Plaintiff filed an application under Title XVI of the Social Security Act for supplemental security income on March 11, 2022. (See Tr. at 15.) After Plaintiff’s application was denied at both the initial and reconsideration levels, Plaintiff requested a hearing before an ALJ. Following a hearing, (id. at 30-68), the ALJ issued an unfavorable decision denying Plaintiff’s application for social security benefits, (id. at 11-29). The Appeals Council denied Plaintiff’s subsequent request for review, (id. at 1-6), making the ALJ’s decision the final decision of the Commissioner. Plaintiff accordingly seeks judicial review of the ALJ’s unfavorable decision denying his application for supplemental security income under the Social Security Act. Standard of Review The Court’s review of the ALJ’s decision denying Plaintiff’s application for benefits under the Social Security Act is limited to whether the decision “complies with the relevant legal requirements and is supported by substantial evidence in the record as a whole.” Halverson v. Astrue, 600 F.3d 922, 929 (8th Cir. 2010) (quoting Ford v. Astrue, 518 F.3d 979, 981 (8th Cir. 2008)). Put another way, “we will affirm if the ALJ made no legal error and the ALJ’s decision is supported by substantial evidence on the record as a whole.” Cropper v. Dudek, 136 F.4th 809, 813 (8th Cir. 2025) (internal quotation marks omitted). “Substantial evidence is less than a preponderance of the evidence, but is ‘such relevant evidence as a reasonable mind would find adequate to support the [ALJ’s] conclusion.’” Grable v. Colvin, 770 F.3d 1196, 1201 (8th Cir. 2014) (quoting Davis v. Apfel, 239 F.3d 962, 966 (8th Cir. 2001)). To determine whether existing evidence is substantial, the Court takes into account “evidence that detracts from the [ALJ’s] decision as well as evidence that supports it.” Cline v. Colvin, 771 F.3d 1098, 1102 (8th Cir. 2014) (internal quotation marks omitted). “If the ALJ’s decision is supported by substantial evidence, [the Court] may not reverse even if substantial evidence would support the opposite outcome or [the Court] would have decided differently.” Smith v. Colvin, 756 F.3d 621, 625 (8th Cir. 2014) (citing Davis, 239 F.3d at 966). On judicial review of the ALJ’s decision, the Court does not “re-weigh the evidence presented to the ALJ,” Guilliams v. Barnhart, 393 F.3d 798, 801 (8th Cir. 2005) (citing Baldwin v. Barnhart, 349 F.3d 549, 555 (8th Cir. 2003)), and must “defer heavily to the findings and conclusions of the [ALJ],” Hurd v. Astrue, 621 F.3d 734, 738 (8th Cir. 2010). Discussion I. ALJ’s Decision In the ALJ's decision, the ALJ conducted the required five-step sequential evaluation. See 20 C.F.R. § 416.920. At Step One, the ALJ found that Plaintiff had not engaged in substantial gainful activity since his filing date, March 11, 2022 (the effective date of his disability). (Tr. at 17.) At Step Two, the ALJ found that Plaintiff had (1) a severe impairment of migraines, (2) non-severe physical impairments of “obstructive sleep apnea, myoclonus, and obesity,” and (3) non-severe mental impairments of “bipolar disorder, generalized anxiety disorder, agoraphobia with panic disorder, autism spectrum disorder, posttraumatic stress disorder (‘PTSD’), methamphetamine abuse, cannabis dependence in remission, alcohol use disorder in remission, and Adderall use disorder in early remission.” (Tr. at 17-18.) In considering the “paragraph B” criteria for mental functioning, the ALJ found a mild limitation in interacting with others and no limitations in the other three areas of mental functioning (understanding, remembering, or applying information; concentrating, persisting, or maintaining pace; and adapting or managing himself). (Tr. at 18-19.) The ALJ found the prior administrative findings of the state psychological consultants persuasive. (Tr. at 18-19.) At Step Three, the ALJ concluded that neither the severe nor non-severe impairments Plaintiff suffered from individually or collectively met or medically equaled a Listed Impairment. (Id. at 20.) At Step Four, the ALJ established the following residual functional capacity (“RFC”), which is the “most [Plaintiff] can do” despite any “physical and mental limitations that affect what [he] can do in a work setting.” 20 C.F.R. § 416.945(a)(1). In formulating the RFC, the ALJ considered Plaintiff’s symptoms and the extent to which they could reasonably be accepted as consistent with the objective medical evidence and other evidence pursuant to 20 C.F.R. § 416.929 and SSR 16-3p, in addition to medical opinions and prior administrative medical findings pursuant to 20 C.F.R. § 416.920c. The ALJ noted that the record documented an official diagnosis of migraines by an acceptable medical source and that Plaintiff reported life-long migraines which impair him “for days at a time,” and cause poor concentration and pain which feels “like he is being hit in the back of the head with a ball-peen hammer.” (Tr. at 21.) Further, the ALJ considered Plaintiff’s statements that he used to have migraines four to five days per week, but at the time of his hearing they occurred four to five times per month with each migraine lasting three to four days. (Id.) The ALJ noted Plaintiff’s testimony that when he has a migraine “he has to lie in a room” and that he sleeps all day for four to five days of the week.

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Bluebook (online)
Robert Westan Parratt v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/robert-westan-parratt-v-social-security-administration-mowd-2026.