Ross v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedAugust 18, 2022
Docket3:21-cv-00186
StatusUnknown

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

Opinion

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

KEVIN ROSS PLAINTIFF

V. No. 3:21-CV-00186-ERE

KILOLO KIJAKAZI, Acting Commissioner of Social Security DEFENDANT

ORDER Plaintiff Kevin Ross appeals the final decision of the Commissioner of the Social Security Administration denying his Title II application for disability insurance benefits. For reasons set out below, the decision of the Commissioner is AFFIRMED. I. BACKGROUND On January 2, 2019, Mr. Ross protectively filed an application for benefits due to deep vein thrombosis in the left hip, a cervical spine disc replacement, a bulging disc in the lumbar spine, a benign tumor in the sinus cavity, syncope, aortic blockage, migraines, and flat feet. Tr. 10, 195. Mr. Ross’ claim was denied initially and upon reconsideration. At Mr. Ross’ request, an Administrative Law Judge (“ALJ”) held a hearing on October 6, 2020, where Mr. Ross appeared with his lawyer, and the ALJ heard testimony from Mr. Ross and a vocational expert (“VE”). Tr. 30-61. The ALJ issued a decision on November 13, 2020, finding that Mr. Ross was not disabled. Tr. 7-28. The Appeals Council denied Mr. Ross’ request for review, making the ALJ’s decision the Commissioner’s final decision. Tr. 1-6.

Mr. Ross, who was forty-six years old at the time of the hearing, attended two years of college and has past relevant work experience as a backhoe operator, dump truck driver, concrete mixing truck driver, and tow truck driver. Tr. 22, 54-55.

II. THE ALJ’s DECISION1 The ALJ found that Mr. Ross had not engaged in substantial gainful activity since December 10, 2018, the alleged onset date. Tr. 12. The ALJ concluded that Mr. Ross had the following severe impairments: lumbar degenerative disc disease;

cervical degenerative disc disease post cervical fusion; peripheral neuropathy; osteoarthritis; and deep venous thrombosis. Id. However, the ALJ found that Mr. Ross 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. Tr. 13. According to the ALJ, Mr. Ross had the residual functional capacity (“RFC”) to perform sedentary work, with the following limitations: (1) no climbing ladders, ropes, or scaffolds; (2) only occasional climbing of ramps or stairs, balancing,

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. §§ 404.1520(a)-(g). stooping, kneeling, crouching, or crawling; (3) no exposure to unprotected heights in the workplace; (4) no use of lower extremities for foot control operation duties;

and (5) only occasional reaching overhead bilaterally. Tr. 14. In response to hypothetical questions incorporating the above limitations, the VE testified that there were unskilled jobs available with these limitations, such as

document preparer and surveillance system monitor. Tr. 55-56. Accordingly, the ALJ determined that Mr. Ross could perform a significant number of jobs existing in the national economy, and found he was not disabled. 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. Mr. Ross’s Arguments for Reversal Mr. Ross contends that the Commissioner’s decision is not supported by substantial evidence. He argues that the ALJ erred in finding that he could perform

the prolonged sitting necessary for sedentary work, and he challenges the ALJ’s omission of any neck movement limitations in his RFC. After careful review of the record and the parties’ briefs, the Court affirms the Commissioner’s decision for the following reasons.

1. Substantial Evidence Supports Sedentary Work RFC

Mr. Ross asserts that substantial evidenced does not support the ALJ’s finding that he can perform the prolonged sitting required for sedentary work. Doc. 14. At the hearing, Mr. Ross testified that he could sit in one position for only about thirty minutes, and that he must constantly change positions when sitting. Tr. 16, 49. This testimony contradicts the ALJ’s finding that he could perform sedentary work, which requires being seated for approximately six hours per workday. See Social Security

Ruling (“SSR”) 96-9p, 1996 WL 374185, at *3. But an ALJ is not required to accept a claimant’s testimony as true. Pierce v. Kijakazi, 22 F.4th 769, 772 (8th Cir. 2022). Here, the ALJ thoroughly reviewed the medical records and found that the

limitations expressed by Mr. Ross were not consistent with the medical evidence and other evidence of record. Tr. 17. The ALJ noted a “lack of additional treatment, abnormal physical examination findings, and lack of therapy.” Tr. 21.

The Court should normally defer to an ALJ’s credibility determination. Grindley v. Kijakazi, 9 F.4th 622, 630 (8th Cir. 2021). An ALJ’s brevity is not reversible error so long as the ALJ’s reasoning allows for “appropriate judicial

review.” Id. When evaluating the credibility of a claimant’s subjective complaints, an ALJ must consider the Polaski factors, which include “the claimant’s prior work history; daily activities; duration, frequency, and intensity of pain; dosage, effectiveness and side effects of medication; precipitating and aggravating factors;

and functional restrictions.” Halverson v. Astrue, 600 F.3d 922, 931 (8th Cir. 2010) (quotation omitted) (citing Polaski v. Heckler, 739 F.2d 1320 (8th Cir. 1984)).

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Related

Halverson v. Astrue
600 F.3d 922 (Eighth Circuit, 2010)
Buckner v. Astrue
646 F.3d 549 (Eighth Circuit, 2011)
Slusser v. Astrue
557 F.3d 923 (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)
Veronica Grindley v. Kilolo Kijakazi
9 F.4th 622 (Eighth Circuit, 2021)
Alan Pierce v. Kilolo Kijakazi
22 F.4th 769 (Eighth Circuit, 2022)

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