Watson v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedMarch 21, 2025
Docket3:24-cv-00059
StatusUnknown

This text of Watson v. Social Security Administration (Watson 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
Watson v. Social Security Administration, (E.D. Ark. 2025).

Opinion

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

ISIAH A. WATSON PLAINTIFF

V. Case No. 3:24-CV-00059-DPM-BBM

LELAND DUDEK, Acting Commissioner, Social Security Administration1 DEFENDANT

RECOMMENDED DISPOSITION

This Recommended Disposition (“Recommendation”) has been sent to United States District Judge D. P. Marshall Jr. 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 objection; and (2) be received by the Clerk of this Court within fourteen (14) days of the date of this Recommendation. If you do not file objections, Judge Marshall may adopt this Recommendation without independently reviewing all of the evidence in the record. By not objecting, you may waive the right to appeal questions of fact. I. INTRODUCTION On July 8, 2021, Plaintiff Isiah A. Watson (“Watson”) filed a Title II application for a period of disability and disability insurance benefits. (Tr. at 11). In the application, he alleged disability beginning on November 1, 2016. Id. The application was denied initially and on reconsideration. Id. After conducting a hearing, an Administrative Law Judge

1 As of the date of this Order, Leland Dudek serves as Acting Commissioner of the Social Security Administration. Pursuant to Federal Rule of Civil Procedure 25(d), Acting Commissioner Dudek is automatically substituted as the Defendant. (“ALJ”) denied Watson’s application by written decision, dated April 7, 2023. (Tr. at 11– 24). The Appeals Council denied Watson’s request for review of the ALJ’s decision on

January 19, 2024. (Tr. at 1–6). The ALJ’s decision now stands as the final decision of the Commissioner, and Watson has requested judicial review. For the reasons stated below, the Court recommends that the Commissioner’s decision be affirmed. II. THE COMMISSIONER’S DECISION Watson last met the insured status requirements of the Social Security Act on

December 31, 2020.2 (Tr. at 14). Watson was 17 years old on the alleged onset date of disability—November 1, 2016—and has not engaged in substantial gainful activity from the alleged onset date through his date last insured.3 (Tr. at 14, 217). At Step Two, the ALJ determined that Watson had the following severe impairments: idiopathic neuropathy, syringomyelia, paresthesia, cervicalgia, and thoracic spondylosis. (Tr. at 14).

At Step Three, the ALJ determined that Watson’s impairments did not meet or equal a Listing.4 (Tr. at 16–18). The ALJ found that Watson has the residual functional capacity

2 For Title II applications, a claimant must establish disability before the date last insured. (Tr. at 12).

3 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).

4 20 C.F.R. Part 404, Subpt. P, Appendix 1 (20 C.F.R. §§ 416.920(d), 416.925, and 416.926). The Listings define impairments that would prevent an adult, regardless of his age, education, or work experience, from performing any gainful activity, not just “substantial gainful activity.” Sullivan v. Zebley, (“RFC”) to perform work at the light exertional level, with the following additional limitations: (1) cannot climb ladders, ropes, and/or scaffolds; (2) can no more than occasionally stoop; (3) can no more than frequently climb ramps and stairs; (4) can no more

than frequently crouch, kneel, and crawl; (5) must avoid concentrated exposure to “excessive vibration, extreme cold, hazardous machinery, and unprotected heights”; (6) can no more than frequently handle and finger bilaterally; and (7) can have no more than occasional exposure to irritants, such as “fumes, odors, dust, and gasses, and to poorly ventilated areas.” (Tr. at 18).

At Step Four, the ALJ found that Watson had no past relevant work. (Tr. at 22–24). Finally, at Step Five, relying upon vocational expert (“VE”) testimony, the ALJ found, based on Watson’s age, education, work experience and RFC, that there are jobs in the national economy that Watson can perform. (Tr. at 22). Therefore, the ALJ concluded that Watson was not disabled from the alleged onset date through the date last insured. (Tr. at

24). 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

493 U.S. 521, 532 (1990) (internal citations omitted). That is, if an adult is not actually working and his impairment matches or is equivalent to a listed impairment, he is presumed unable to work and is awarded benefits without a determination of whether he actually can perform his prior work or other work. Id. 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.

Haley v. Massanari, 258 F.3d 742, 747 (8th Cir. 2001) (internal quotations and 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, 587 U.S. 97, 103 (2019) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 217 (1938)). “It means—and means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Id. B. Watson’s Arguments on Appeal Watson contends that the evidence supporting the ALJ’s decision is less than substantial. (Doc. 9 at 16–26). Specifically, Watson argues that: (1) the ALJ failed to provide a comprehensive analysis of Watson’s subjective complaints, id. at 16–19; (2) the ALJ failed to give proper deference to Watson’s medical records, id.

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Related

Sullivan v. Zebley
493 U.S. 521 (Supreme Court, 1990)
McCoy v. Astrue
648 F.3d 605 (Eighth Circuit, 2011)
Renstrom v. Astrue
680 F.3d 1057 (Eighth Circuit, 2012)
Charles Miller v. Carolyn W. Colvin
784 F.3d 472 (Eighth Circuit, 2015)
Karl Wright v. Carolyn W. Colvin
789 F.3d 847 (Eighth Circuit, 2015)
Tracy Milam v. Carolyn W. Colvin
794 F.3d 978 (Eighth Circuit, 2015)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)

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Watson v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/watson-v-social-security-administration-ared-2025.