Ruiz v. Kijakazi

CourtDistrict Court, E.D. Missouri
DecidedSeptember 30, 2024
Docket4:23-cv-00418
StatusUnknown

This text of Ruiz v. Kijakazi (Ruiz 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
Ruiz v. Kijakazi, (E.D. Mo. 2024).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI EASTERN DIVISION

ANGEL RUIZ, ) ) Plaintiff, ) ) vs. ) Case No. 4:23-CV-418-ACL ) MARTIN O’MALLEY, ) Commissioner of Social Security ) Administration, ) ) Defendant. )

MEMORANDUM

Plaintiff Angel Ruiz brings this action pursuant to 42 U.S.C. § 405(g), seeking judicial review of the Social Security Administration Commissioner’s denial of her application for Disability Insurance Benefits (“DIB”) under Title II of the Social Security Act. An Administrative Law Judge (“ALJ”) found that Ruiz was not disabled because she could perform jobs existing in significant numbers in the national economy. This matter is pending before the undersigned United States Magistrate Judge, with consent of the parties, pursuant to 28 U.S.C. § 636(c). A summary of the entire record is presented in the parties’ briefs and is repeated here only to the extent necessary. For the following reasons, the decision of the Commissioner will be reversed. I. Procedural History Ruiz filed her application for benefits on November 21, 2019. (Tr. 424-31.) She claimed she became unable to work on September 25, 2019, due to hip pain, back pain, anxiety, and depression. (Tr. 459, 463.) Ruiz was 29 years of age at her alleged onset of disability date. Page 1 of 16 (Tr. 25.) Her application was denied initially. (Tr. 70-93.) On May 17, 2022, an ALJ issued a decision finding Ruiz not disabled. (Tr. 13-26.) On February 15, 2023, the Appeals Council denied Ruiz’s claim for review. (Tr. 1-4.) Thus, the decision of the ALJ stands as the final decision of the Commissioner. See 20 C.F.R. §§ 404.981, 416.1481.

In this action, Ruiz first argues that the ALJ “failed to properly evaluate medical opinion evidence.” (Doc. 18 at 3.) She next argues that the decision “fails to properly evaluate Plaintiff’s pain and other subjective symptoms.” Id. at 6. Finally, Plaintiff contends that the “RFC is not supported by substantial evidence.” Id. at 11. II. The ALJ’s Determination

The ALJ first found that Ruiz met the insured status requirements of the Social Security Act through September 30, 2022. (Tr. 15.) He stated that Ruiz has not engaged in substantial gainful activity since her alleged onset date. Id. In addition, the ALJ concluded that Ruiz had the following severe impairments: obesity; disorders of the lumbar and cervical spine; borderline intellectual functioning; depressive, bipolar and related disorders; anxiety; PTSD; pain disorder with psychological factors; chronic pain syndrome; asthma; left hip dysfunction; osteoarthritis; carpal tunnel syndrome of the right hand; and neuropathy of the left wrist (20 CFR 404.1520(c). Id. The ALJ found that Ruiz did not have an impairment or combination of impairments that met or medically equaled the severity of one of the listed impairments. (Tr. 17.) As to Ruiz’s RFC, the ALJ stated:

After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) except she can never climb ladders, ropes and scaffolds. The individual can occasionally climb ramps and stairs. The individual can occasionally stoop, crouch, kneel and crawl. The individual can Page 2 of 16 handle objects, that is gross manipulation, frequently with the bilateral upper extremities. The individual can finger, that is fine manipulation of items no smaller than the size of paper clips frequently with the bilateral upper extremities. The individual can feel frequently, with the bilateral upper extremities. The individual can have occasional exposure to irritants such as fumes, odors, dust, gasses, and poor ventilation. The individual can have no use of hazardous machinery and no exposure to unshielded moving mechanical parts. No exposure to unprotected heights. No exposure to extreme heat, humidity and cold. The claimant is able to understand, remember and carry out simple instructions in the performance of simple, routine and repetitive tasks. The individual can use judgment to make simple work-related decisions, and the individual can have occasional changes in routine work settings. The individual can have superficial contact with the public (where superficial is defined to mean the contact is incidental and not an essential function of the job) and only occasional interaction with coworkers and supervisors. She is limited to jobs in which she could work in proximity to but not in coordination with coworkers and supervisors.

(Tr. 19-20.) The ALJ found that Ruiz was unable to perform any past relevant work. (Tr. 25.) He stated that there were other jobs existing in significant numbers in the national economy that Ruiz could perform, such as housekeeper and retail clerk. (Tr. 25-26.) The ALJ therefore concluded that Ruiz was not disabled. (Tr. 26.) The ALJ’s final decision reads as follows: Based on the application for a period of disability and disability insurance benefits protectively filed on November 21, 2019, the claimant is not disabled under sections 216(i) and 223(d) of the Social Security Act.

Id.

Page 3 of 16 III. Applicable Law III.A. Standard of Review The decision of the Commissioner must be affirmed if it is supported by substantial evidence on the record as a whole. 42 U.S.C. § 405(g); Richardson v. Perales, 402 U.S. 389,

401 (1971); Estes v. Barnhart, 275 F.3d 722, 724 (8th Cir. 2002). Substantial evidence is less than a preponderance of the evidence, but enough that a reasonable person would find it adequate to support the conclusion. Johnson v. Apfel, 240 F.3d 1145, 1147 (8th Cir. 2001). This “substantial evidence test,” however, is “more than a mere search of the record for evidence supporting the Commissioner’s findings.” Coleman v. Astrue, 498 F.3d 767, 770 (8th Cir. 2007) (internal quotation marks and citation omitted). “Substantial evidence on the record as a whole . . . requires a more scrutinizing analysis.” Id. (internal quotation marks and citations omitted). To determine whether the Commissioner’s decision is supported by substantial evidence on the record as a whole, the Court must review the entire administrative record and consider:

1. The credibility findings made by the ALJ.

2. The plaintiff’s vocational factors.

3. The medical evidence from treating and consulting physicians.

4. The plaintiff’s subjective complaints relating to exertional and non-exertional activities and impairments.

5. Any corroboration by third parties of the plaintiff’s impairments.

6. The testimony of vocational experts when required which is based upon a proper hypothetical question which sets forth the Page 4 of 16 claimant’s impairment.

Stewart v. Secretary of Health & Human Servs.,

Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Bertha Eichelberger v. Jo Anne B. Barnhart
390 F.3d 584 (Eighth Circuit, 2004)
Kirby v. Astrue
500 F.3d 705 (Eighth Circuit, 2007)
Coleman v. Astrue
498 F.3d 767 (Eighth Circuit, 2007)
Kathleen J. Papesh v. Carolyn W. Colvin
786 F.3d 1126 (Eighth Circuit, 2015)
Jeffrey Walker v. Commissioner, Social Security
911 F.3d 550 (Eighth Circuit, 2018)

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Ruiz v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ruiz-v-kijakazi-moed-2024.