Taylor v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedAugust 9, 2021
Docket4:20-cv-00925
StatusUnknown

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

Opinion

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

STEPHANIE ALICIA TAYLOR PLAINTIFF

V. NO. 4:20-CV-00925-JTK

COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION DEFENDANT

ORDER

I. Introduction:

Plaintiff, Stephanie Alicia Taylor (“Taylor”), applied for disability benefits on February 10, 2018, alleging a disability onset date of January 3, 2018. (Tr. at 16). The claim was denied initially and upon reconsideration. Id. After conducting a hearing, the Administrative Law Judge (“ALJ”) denied Taylor’s application on October 21, 2019. (Tr. at 26). The Appeals Council denied her request for review. (Tr. at 1). The ALJ=s decision now stands as the final decision of the Commissioner, and Taylor has requested judicial review. For the reasons stated below, the Court1 affirms the decision of the Commissioner. II. The Commissioner=s Decision: The ALJ found that Taylor had not engaged in substantial gainful activity since the alleged onset date of January 3, 2018.2 (Tr. at 18). The ALJ found, at Step Two, that Taylor had the following severe impairments: degenerative disc disease, status post knee arthroscopy, diabetes

1 The parties have consented in writing to the jurisdiction of a United States Magistrate Judge.

2 The ALJ followed the required five-step sequence 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; (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), 416.920(a)-(g). mellitus with diabetic neuropathy, depression, and history of opiate dependence. Id. After finding that Taylor’s impairments did not meet or equal a listed impairment (Tr. at 19), the ALJ determined that Taylor had the residual functional capacity (“RFC”) to perform work at the light exertional level, with exceptions: (1) she could no more than occasionally stoop, kneel, crouch, and crawl; (2) she could no more than occasionally reach overhead; (3) she could perform

work where the interpersonal contact is only incidental to the work performed (meaning a limited amount of meet and greet and no sales or solicitation); (5) she could perform tasks that can be learned in 30 days and require little independent judgment to perform those tasks; and (6) she could no more than occasionally tolerate changes in a routine work setting. (Tr. at 20). At Step Four, based on testimony from a Vocational Expert (“VE”), the ALJ found that Taylor was capable of performing past relevant work as a deli worker and office cleaner. (Tr. at 25). Therefore, the ALJ found that Taylor 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

2 would have supported an opposite decision.”

Reed v. Barnhart, 399 F.3d 917, 920 (8th Cir. 2005) (citations omitted). In clarifying the “substantial evidence” standard applicable to review of administrative decisions, the Supreme Court has explained: “And whatever the meaning of ‘substantial’ in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence . . . ‘is more than a mere scintilla.’” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (quoting Consolidated Edison Co. v. NLRB, 59 S. Ct. 206, 217 (1938)). “It means—and means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Id. B. Taylor=s Arguments on Appeal Taylor contends that substantial evidence does not support the ALJ=s decision to deny benefits. She argues that: (1) the ALJ erred by not finding obesity to be a severe impairment; (2) the ALJ did not properly consider Taylor’s subjective complaints; (3) the ALJ did not fully develop the record; (4) the RFC did not incorporate all of Taylor’s limitations; and (5) Taylor could not return to her past relevant work. For the following reasons, the Court finds that substantial evidence

supports the ALJ=s decision. Taylor suffered from back, neck, and knee pain, but objective imaging showed no more than moderate conditions, which the ALJ discussed. (Tr. 21-22, 420-496, 939-974). Knee surgery was successful. (Tr. at 829, 1083). Medications mitigated Taylor’s pain, and she refused to take narcotics for pain. (Tr. at 64, 940). Impairments that are controllable or amenable to treatment do not support a finding of total disability. Mittlestedt v. Apfel, 204 F.3d 847, 852 (8th Cir. 2000). She also had diabetes and diabetic neuropathy. But medication kept blood sugars in a reasonable range, and although her doctors recommended a diabetic diet, at the hearing, Taylor

3 said she did not follow such a diet. (Tr. at 66-67, 1131). Her doctors also suggested that she exercise and lose weight. (Tr. at 502). A physician’s recommendation to exercise suggests that a claimant has an increased functional capacity. See Moore v. Astrue, 572 F.3d 520, 524 (8th Cir. 2009). Intact movement and sensation in her extremities, as well as normal gait and station, indicated that Taylor’s neuropathy was not disabling. (Tr. at 608-628, 786, 1094).

Taylor alleged anxiety and depression, but she treated conservatively with medication and counseling. In early 2018, Taylor said her mood was improved and she denied anxiety. (Tr. at 803, 1131). Moreover, mental status examinations showed logical and goal-directed thought process and appropriate mood. (Tr. at 628, 803, 1094, 1131). At a May 2018 consultative mental examination, Taylor’s showed no apparent distress or anxiety, and her mood, attitude, and affect were good (the clinician noted that Taylor exaggerated her symptoms). (Tr. at 644-648). She admitted that her mental health problems were controlled by medication. (Tr. at 502, 644-648, 1131). Taylor first contends that the ALJ should have discussed her obesity and found it to be a

severe impairment. Taylor had a BMI of 30.5, and a BMI of 30 or above is considered obese. (Doc. No. 17 at p. 16). However, Taylor said she had lost ten pounds at the hearing, and her doctors encouraged her to exercise. (Tr. at 64-67).

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Taylor v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/taylor-v-social-security-administration-ared-2021.