Travis v. Kijakazi

CourtDistrict Court, E.D. Missouri
DecidedDecember 12, 2024
Docket1:23-cv-00171
StatusUnknown

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

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MISSOURI SOUTHEASTERN DIVISION

CHASITY A. TRAVIS, ) ) Plaintiff, ) ) v. ) Case No. 1:23-CV-171-SNLJ ) CAROLYN COLVIN,1 ) Acting Commissioner of the Social ) Security Administration, ) ) Defendant. )

MEMORANDUM AND ORDER

The Commissioner of the Social Security Administration denied plaintiff Chasity Travis’s application for Disability Insurance Benefits and Supplemental Security Income under Titles II and XVI of the Social Security Act. Plaintiff now seeks judicial review. The matter has been fully briefed. As discussed below, this Court will REVERSE and REMAND the Commissioner’s decision for further proceedings in accordance with this order.

1 Carolyn W. Colvin is now the Acting Commissioner of Social Security. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Carolyn W. Colvin is substituted for Commissioner Martin O’Malley as the defendant in this suit.

1 I. Procedural History Plaintiff Travis was born in 1975. She alleges disability since October 1, 2016.

Plaintiff’s claims were initially denied, and, on December 5, 2022, following a hearing, the Administrative Law Judge (“ALJ”) found plaintiff was not under a “disability” as defined by the Act. The ALJ determined that plaintiff had severe impairments that included lumbar degenerative disc disease with a history of fusion, degenerative disc disease of the cervical spine, osteoarthritis of the left hip, asthma, obesity, and an anxiety disorder. However, the ALJ found she did not have an impairment or combination of

impairments listed in or medically equal to one contained in 20 C.F.R. part 404, subpart P, appendix 1. The December 5, 2022 ALJ decision was in response to a remand order by the Appeals Council that reversed the ALJ’s May 26, 2021 decision. The Appeals Council ordered the ALJ to clarify two aspects of his May decision. The May decision stated that

plaintiff would need to change positions for a few minutes every hour but did not specify the frequency of the need to change positions nor the length of time needed to remain in the alternate position. The Council also asked the ALJ to address whether the claimant needed a hand-held assistive device to stand. Plaintiff appeals the December 5, 2022 decision.

2 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), 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), 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)(1), 416.920(a)(1). 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

3 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).

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. 20 C.F.R. §§ 404.1520(a)(4)(iii), (d); 416.920(a)(3)(iii), (d). Fourth, if the claimant’s impairment is severe, but it 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 his or her 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) (internal quotations omitted); 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, 831F.3d 1015, 1020 (8th Cir. 2016). Thus, “there is no requirement that an RFC finding be supported by a specific medical 4 opinion.” Hensley v. Colvin, 829 F.3d 926, 932 (8th Cir. 2016). Ultimately, the claimant is responsible for providing evidence relating to his RFC and the Commissioner is

responsible for developing the claimant’s “complete medical history, including arranging for a consultative examination(s) if necessary, and making every reasonable effort to help [the claimant] get medical reports from [the claimant’s] own medical sources.” 20 C.F.R. §§ 404.1545(a)(3), 416.945(a)(3). If, upon the findings of the ALJ, it is determined the claimant retains the RFC to perform past relevant work, he or she is not disabled. 20 C.F.R. §§ 404.1520(a)(4)(iv), 416.920(a)(4)(iv).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Carroll F. Dixon v. Jo Anne B. Barnhart
353 F.3d 602 (Eighth Circuit, 2003)
Lynn Ulman v. Commissioner of Social Security
693 F.3d 709 (Sixth Circuit, 2012)
Kirby v. Astrue
500 F.3d 705 (Eighth Circuit, 2007)
Coleman v. Astrue
498 F.3d 767 (Eighth Circuit, 2007)
McNamara v. Astrue
590 F.3d 607 (Eighth Circuit, 2010)
Jana Turpin v. Carolyn W. Colvin
750 F.3d 989 (Eighth Circuit, 2014)
Tracy Milam v. Carolyn W. Colvin
794 F.3d 978 (Eighth Circuit, 2015)
Travis Chaney v. Carolyn W. Colvin
812 F.3d 672 (Eighth Circuit, 2016)
Marcus Hensley v. Carolyn W. Colvin
829 F.3d 926 (Eighth Circuit, 2016)
Amy Thomas v. Nancy A. Berryhill
881 F.3d 672 (Eighth Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Travis v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/travis-v-kijakazi-moed-2024.