Shaw v. Kijakazi

CourtDistrict Court, E.D. Missouri
DecidedAugust 25, 2022
Docket1:21-cv-00086
StatusUnknown

This text of Shaw v. Kijakazi (Shaw 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
Shaw v. Kijakazi, (E.D. Mo. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEASTERN DIVISION

MARY JANE SHAW, ) ) Plaintiff, ) ) v. ) Case No. 1:21-CV-86-SNLJ ) KILOLO KIJAKAZI, 1 ) Commissioner of the Social ) Security Administration, ) ) Defendant. )

MEMORANDUM AND ORDER The Commissioner of the Social Security Administration denied plaintiff Mary Jane Shaw’s application for Disability Insurance Benefits under Title II of the Social Security Act. Plaintiff now seeks judicial review, alleging that the Administrative Law Judge (“ALJ”) erred by concluding that plaintiff’s irritable bowel syndrome (“IBS”) was not a severe impairment. The Commissioner filed a response memorandum, but the plaintiff did not file a reply, and the time for doing so has now passed. As explained below, the ALJ’s decision is supported by substantial evidence on the record as a whole and is affirmed.

1 Kilolo Kijakazi became the Acting Commissioner of Social Security on July 9, 2021. Under Rule 25(d) of the Federal Rules of Civil Procedure, Kilolo Kijakazi is substituted for Andrew Saul as the defendant in this suit. I. Procedural History Plaintiff was born in 1965. Plaintiff filed an application for Disability Insurance

Benefits on February 10, 2020, alleging an onset of disability of January 2, 2020. She also indicated she stopped working because she was terminated from her job due to workforce reduction. [Tr. 175]. Her claim was disapproved, and plaintiff requested a hearing by an ALJ. After a hearing, the ALJ issued an unfavorable decision. Plaintiff filed for review by the Appeals Council, and the Appeals Council denied plaintiff’s request for review. Thus, the ALJ’s decision is the final decision of the Commissioner. Plaintiff seeks judicial

review. II. Disability Determination—Five Steps A disability is defined as the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which . . . has lasted or can be expected to last for a continuous period of not less than 12 months . . . .”

42 U.S.C. § 423(d)(1)(A), id. § 1382c(a)(3)(A). A claimant has a disability “only if his physical or mental impairment or impairments are of such severity that he is not only unable to do his previous work but cannot, considering his age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy. . . .” Id. § 423(d)(2)(A), id. § 1382c(a)(3)(B).

The Commissioner follows a five-step sequential process when evaluating whether the claimant has a disability. 20 C.F.R. §§ 404.1520(a), 416.920(a). First, the Commissioner considers the claimant’s work activity. If the claimant is engaged in substantial gainful activity, the claimant is not disabled. 20 C.F.R. §§ 404.1520(a)(4)(i), 416.920(a)(4)(i).

Second, if the claimant is not engaged in substantial gainful activity, the Commissioner looks to see “whether the claimant has a severe impairment that significantly limits the claimant’s physical or mental ability to perform basic work activities.” Dixon v. Barnhart, 353 F.3d 602, 605 (8th Cir. 2003); see also 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). “An impairment is not severe if it amounts only to a slight abnormality that would not significantly limit the claimant’s physical or mental

ability to do basic work activities.” Kirby v. Astrue, 500 F.3d 705, 707 (8th Cir. 2007); see also 20 C.F.R. §§ 404.1520(c), 404.1520a(d), 416.920(c), 416.920a(d). “The severity requirement cannot be satisfied when medical evidence shows that the person has the ability to perform basic work activities, as required in most jobs.” Soc. Sec. Ruling 85-28 (listing basic work activities). The claimant carries the burden to show that an impairment

is severe. Kirby, 500 F.3d at 707–08. Third, if the claimant has a severe impairment, the Commissioner considers the impairment’s medical severity. If the impairment meets or equals one of the presumptively disabling impairments listed in the regulations, the claimant is considered disabled— regardless of age, education, and work experience—and this ends the analysis. 20 C.F.R.

§§ 404.1520(a)(4)(iii), (d); 416.920(a)(3)(iii), (d). Fourth, if the claimant’s severe impairment does not meet or equal one of the presumptively disabling impairments, the Commissioner assesses whether the claimant retains the “residual functional capacity” (“RFC”) to perform any past relevant work. 20 C.F.R. §§ 404.1520(a)(4)(iv), 404.1545(a)(5)(i), 416.920(a)(4)(iv), 416.945(a)(5)(i). An RFC is “defined wholly in terms of the claimant’s physical ability to perform exertional

tasks or, in other words, what the claimant can still do despite his or her physical or mental limitations.” Lewis v. Barnhart, 353 F.3d 642, 646 (8th Cir. 2003) (cleaned up); see also 20 C.F.R. §§ 404.1545(a)(1), 416.945(a)(1). While an RFC must be based “on all relevant evidence, including the medical records, observations of treating physicians and others, and an individual’s own description of his limitations,” an RFC is nonetheless an “administrative assessment”—not a medical assessment—and, therefore, “it is the

responsibility of the ALJ, not a physician, to determine a claimant’s RFC.” Boyd v. Colvin, 831 F.3d 1015, 1020 (8th Cir. 2016). Thus, “there is no requirement that an RFC finding be supported by a specific medical opinion.” Hensley v. Colvin, 829 F.3d 926, 932 (8th Cir. 2016). Ultimately, the claimant is responsible for providing evidence relating to the RFC and the Commissioner is responsible for developing the claimant’s “complete medical

history. . . .” 20 C.F.R. §§ 404.1545(a)(3), 416.945(a)(3). The claimant is not disabled if the ALJ determines that the claimant retains the RFC to perform past relevant work. 20 C.F.R. §§ 404.1520(a)(4)(iv), 416.920(a)(4)(iv). Fifth, if the claimant’s RFC does not allow the claimant to perform past relevant work, then burden of production shifts to the Commissioner to show that the claimant

maintains the RFC to perform other work that exists in significant numbers in the national economy. See Bladow v. Apfel, 205 F.3d 356, 358–59 n.5 (8th Cir. 2000); 20 C.F.R. §§ 404.1520(a)(4)(v), 416.920(a)(4)(v). Though the burden of production shifts to the commissioner, the claimant keeps the burden of persuasion to prove disability.

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