Sanders v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedApril 13, 2021
Docket4:20-cv-00251
StatusUnknown

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

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF ARKANSAS CENTRAL DIVISION

JOHN L. SANDERS PLAINTIFF

V. NO. 4:20CV00251 BSM-JTR

COMMISSIONER of SOCIAL SECURITY ADMINISTRATION DEFENDANT

RECOMMENDED DISPOSITION

The following Recommended Disposition (“Recommendation”) has been sent to United States District Judge Brian S. Miller. You may file written objections to all or part of this Recommendation. If you do so, those objections must: (1) specifically explain the factual and/or legal basis for your objections; and (2) be received by the Clerk of this Court within fourteen (14) days of this Recommendation. By not objecting, you may waive the right to appeal questions of fact. I. Introduction:

Plaintiff, John L. Sanders (“Sanders”), applied for disability benefits on August 11, 2018, alleging disability beginning on August 3, 2017. (Tr. at 15). After conducting a hearing, the Administrative Law Judge (“ALJ”) denied his application on December 3, 2019. Id. The Appeals Council denied Sanders’s request for review. (Tr. at 1). Thus, the ALJ=s decision now stands as the final decision of the Commissioner. Sanders has filed a Complaint seeking judicial review from this Court. For the reasons stated below, the Court concludes that the Commissioner’s

decision should be affirmed. II. The Commissioner=s Decision: The ALJ found that Sanders had not engaged in substantial gainful activity

since the alleged onset date of August 3, 2017. (Tr. at 17). At Step Two, the ALJ found that Sanders had the following severe impairments: osteoarthritis and degenerative disc disease of the cervical and lumbar spine status post-cervical spine surgery, obesity, obstructive sleep apnea, and a history of left knee surgery. (Tr. at

18). After finding that Sanders’s impairments did not meet or equal a listed impairment (Tr. at 19-20), the ALJ determined that Sanders had the residual

functional capacity (ARFC@) to perform work at the sedentary exertional level, except that: (1) he can only occasionally climb ramps and stairs, but can never climb ladders, ropes, or scaffolds; (2) he can only occasionally balance, stoop, kneel, crawl, and crouch; (3) he can frequently, but not constantly, reach and handle bilaterally;

and (4) he must avoid concentrated exposure to hazards including driving as part of work. (Tr. at 20). The ALJ found that Sanders was unable to perform any of his past relevant

work. (Tr. at 25). At Step Five, the ALJ relied on the testimony of a Vocational Expert ("VE") to find that, based on Sanders's age, education, work experience and RFC, jobs existed in significant numbers in the national economy that he could

perform, including work as a call out operator, a telephone order clerk, and a telephone information clerk. (Tr. at 26). Thus, the ALJ found that Sanders was not disabled. Id.

III. Discussion: A. Standard of Review The 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 whether

it is based on legal error. Miller v. Colvin, 784 F.3d 472, 477 (8th Cir. 2015); see also 42 U.S.C. § 405(g). While “substantial evidence” is that which a reasonable mind might accept as adequate to support a conclusion, “substantial evidence on the

record as a whole” requires a court to engage in a more scrutinizing analysis: “[O]ur review is more than an examination of the record for the existence of substantial evidence in support of the Commissioner’s decision; we also take into account whatever in the record fairly detracts from that decision.” Reversal is not warranted, however, “merely because substantial evidence would have supported an opposite decision.”

Reed v. Barnhart, 399 F.3d 917, 920 (8th Cir. 2005) (citations omitted). The United States Supreme Court recently held that “whatever the meaning

3 of ‘substantial’ is in other contexts, the threshold for such evidentiary sufficiency [in Social Security Disability cases] is not high. Substantial evidence…is more than a

mere scintilla. It means—and means only—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019).

It is not the task of this Court to review the evidence and make an independent decision. Neither is it to reverse the decision of the ALJ because there is evidence in the record which contradicts his findings. The test is whether there is substantial evidence in the record as a whole which supports the decision of the ALJ. Miller,

784 F.3d at 477. B. Sanders=s Arguments on Appeal Sanders contends that substantial evidence does not support the ALJ=s

decision to deny benefits. He argues that: (1) the ALJ did not properly assess medical opinions; (2) the ALJ failed to fully develop the record; (3) the ALJ did not properly analyze Sanders’s subjective complaints; and (4) the ALJ failed to carry his burden of proof at Step Five. After reviewing the record as a whole, the Court concludes

that the ALJ did not err in denying benefits. Sanders’s main medical complaints, and those upon which he bases his case, are PTSD and radiating back pain.

4 As for PTSD, Sanders did receive minimal treatment for the condition, after he was granted a VA disability rating of 33% based on the illness.1 The record only

reflects a handful of therapy appointments in the spring of 2019. (Tr. at 731-738). At those appointments, Sanders’s mental status examinations were normal and the recommended treatment was conservative. Id. Normal clinical findings may support

an ALJ’s decision to deny benefits. Gowell v. Apfel, 242 F.3d 793, 796 (8th Cir. 2001). The therapist observed that Sanders had many friends and family with whom he socialized. Id. Sanders admitted that he took no psychiatric medication, and had never been hospitalized for his condition. Id. He said that he got coffee with friends,

went to bars, and dated. (Tr. at 47-56). The Disability Determination Services psychological experts reviewed the records and determined that mental impairments were non-severe. (Tr. at 77-95). The ALJ considered these opinions, along with

negligible evidence of problems stemming from PTSD, and concurred that mental impairments were non-severe. (Tr. at 18). As for physical impairments, an MRI of Sanders’s cervical spine showed severe central spinal stenosis with broad based disc herniation. (Tr. at 523). To treat

1 Sanders received a total VA disability rating of 100%. (Tr. at 52-53). The ALJ considered this evidence, but properly ruled it to be unpersuasive. (Tr. at 24).The Administration is not bound by the disability ratings of another agency, especially when the record does not justify a disability finding. Pelkey v. Barnhart, 433 F.3d 575, 580 (8th Cir. 2008); Morrison v. Apfel, 146 F.3d 625, 628 (8th Cir. 1998).

5 this condition, Sanders underwent a total disc arthroplasty at C5-C6 in September 2017. Id. After that, he reported decreased radicular pain, and upon examination by

a neurologist, Sanders had normal motor strength with only mild weakness in his lower extremities.2 (Tr.

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