Rowland v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedApril 1, 2022
Docket4:21-cv-00660
StatusUnknown

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

Opinion

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

JEREMY ROWLAND PLAINTIFF

V. No. 4:21-CV-00660-ERE

KILOLO KIJAKAZI, Acting Commissioner of Social Security DEFENDANT

ORDER Plaintiff, Jeremy Rowland, 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 December 16, 2019, Mr. Rowland protectively filed an application for benefits due to post-traumatic stress disorder, fatty liver disease, bulging discs, degenerative disc disease, right hip issues, a torn rotator cuff, torn cartilage in right arm, degenerative joint disease, dislocation in both knees, high blood pressure, high cholesterol, recurrent ulcers, sleep apnea, and status post knee surgeries and ankle surgery. Tr. 93-95. At Mr. Rowland’s request, an Administrative Law Judge (“ALJ”) held a hearing on November 20, 2020, where Mr. Rowland appeared with his lawyer, and the ALJ heard testimony from Mr. Rowland and a vocational expert (“VE”). Tr. 45- 73. The ALJ issued a decision on December 17, 2020, finding that Mr. Rowland was not disabled. Tr. 16-29. The Appeals Council denied Mr. Rowland’s request for

review, making the ALJ’s decision the Commissioner’s final decision. Tr. 5-10. Mr. Rowland, who was forty-three years old at the time of the hearing, has a bachelor’s degree in business administration. Tr. 50-51. He has past relevant work

experience as a bookkeeper. Tr. 52. II. DECISION OF THE ADMINISTRATIVE LAW JUDGE1 The ALJ found that Mr. Rowland had not engaged in substantial gainful activity since October 1, 2019 and he has the following severe impairments:

degenerative disk disease of the lumbar spine, degenerative changes to the right shoulder and bilateral knees and obesity. Tr. 21. However, the ALJ found that Mr. Rowland 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. 23. According to the ALJ, Mr. Rowland has the residual functional capacity (“RFC”) to perform sedentary work, with the following limitations: (1) can only occasionally climb stairs and ramps, stoop, crouch, kneel, and crawl; (2) must avoid

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). climbing ladders, ropes, and scaffolds and should refrain from working at unprotected heights; (3) can frequently reach overhead, but not constantly; (4)

limited or no foot control operation; (5) should avoid temperature extremes and would requires an inside climate controlled environment; and (6) may require a cane for assistance for distance walking but not for sedentary work. Tr. 23.

In response to hypothetical questions incorporating the above limitations, the VE testified Mr. Rowland could perform his past relevant work as a bookkeeper. Tr. 68. The VE also testified that there were unskilled jobs available with these limitations, such as surveillance system monitor and addresser. Tr. 70-71.

Accordingly, the ALJ determined that Mr. Rowland could perform a significant number of other 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. Rowland’s Arguments for Reversal 1. The ALJ’s hypothetical question was incomplete and deviated significantly from the assessed RFC.

Mr. Rowland asserts that the ALJ failed to consider state agency medical consultant Dr. Alice Davidson’s opinion in the hypotheticals. Dr. Davidson concluded that Mr. Rowland could sit six hours in an eight-hour workday. Tr. 99. Sedentary work requires only occasional walking and standing. 20 C.F.R. § 404.1567. Since “occasional” is “up to one-third of the time,” the RFC is not contrary to Dr. Davidson’s assessment. Owens v. Colvin, 727 F.3d 850, 852 (8th Cir. 2013).

The fact that ALJ used the phrase “for the most part” rather than “occasional” is irrelevant. Tr. 67. The ALJ also used the phrase “limited overhead reach” which Mr. Rowland

argues is too vague. However, the VE appeared to understand what the ALJ meant by “limited” and testified that the overhead reaching for bookkeeping would be limited. Tr. 69. Additionally, the ALJ’s hypothetical also included “frequent reaching and handling.” Tr. 67. The ALJ’s decision clearly sets out that Mr. Rowland could perform jobs that required frequent, but not constant, reaching. Tr. 23. Finally,

any error would be harmless because the VE testified, and ALJ concluded, that Mr. Nowland could also perform the job of surveillance system monitor, which requires no reaching. Tr. 28, 70; see DOT #379.367-010.

2. The sequential analysis at Step 4 is not supported by substantial evidence.

Mr. Rowland asserts that “the ALJ’s comparison of the plaintiff’s RFC with the physical and mental demands of the job of bookkeeper was legally insufficient.” Doc. 14. Mr. Rowland correctly points out that the ALJ had a duty to get a VE to clear up any conflicts between the VE’s testimony and the Dictionary of Occupational Titles (“DOT”). Kemp ex rel. Kemp v. Colvin, 743 F.3d 630, 633 (8th Cir. 2014). The ALJ also had a duty to explain the clarification in his ruling. Id. At the hearing, the ALJ and VE discussed the fact that noted that “the DOT does not explain directional reaching.” Tr. 68.

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Related

Halverson v. Astrue
600 F.3d 922 (Eighth Circuit, 2010)
Steven Owens v. Carolyn W. Colvin
727 F.3d 850 (Eighth Circuit, 2013)
Slusser v. Astrue
557 F.3d 923 (Eighth Circuit, 2009)
Vickie Kemp v. Carolyn Colvin
743 F.3d 630 (Eighth Circuit, 2014)
Ronnie Moore, Jr. v. Carolyn W. Colvin
769 F.3d 987 (Eighth Circuit, 2014)
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)

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