Williams v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedOctober 4, 2021
Docket3:20-cv-00281
StatusUnknown

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

Opinion

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

TARA D. WILLIAMS PLAINTIFF

v. NO. 3:20-cv-00281 PSH

KILOLO KIJAKAZI, Acting Commissioner DEFENDANT of the Social Security Administration

MEMORANDUM OPINION AND ORDER

In this case, plaintiff Tara D. Williams (“Williams”) maintains that the findings of an Administrative Law Judge (“ALJ”) are not supported by substantial evidence on the record as a whole.1 Specifically, Williams maintains that her residual functional capacity was not properly assessed. It is her contention that the assessment does not adequately account for her severe pain.

1 The question for the Court is whether the ALJ’s findings are supported by “substantial evidence on the record as a whole and not based on any legal error.” See Sloan v. Saul, 933 F.3d 946, 949 (8th Cir. 2019). “Substantial evidence is less than a preponderance, but enough that a reasonable mind would accept it as adequate to support the [ALJ’s] conclusion.” See Id. “‘Legal error may be an error of procedure, the use of erroneous legal standards, or an incorrect application of the law.’” See Lucus v. Saul, 960 F.3d 1066, 1068 (8th Cir. 2020) (quoting Collins v. Astrue, 648 F.3d 869, 871 (8th Cir. 2011) (citations omitted)). The record reflects that Williams was born on October 14, 1978, and was thirty-eight years old on October 25, 2016, the amended alleged onset

date.2 In her application for disability insurance benefits, she alleged that she became disabled as a result of, inter alia, her severe pain. Williams has experienced pain in her neck, shoulders, and back since

well before the amended alleged onset date.3 She fell down stairs in November of 2005 and required back surgery to repair a ruptured disc and “broken spinous process.” See Transcript at 477. She fell down stairs again in November of 2011 and required back surgery to repair ruptured discs and

remove a bone spur. See Transcript at 477.

2 The alleged onset date in this case is a bit confusing. In Williams’ application for disability insurance benefits, she alleged that she became disabled beginning on April 24, 2014. The ALJ observed at the outset of the administrative hearing, though, that there is “a prior unfavorable decision dated October 19 of [2016].” See Transcript at 54. Given his observation, the alleged onset date was amended to October 25, 2016. See Transcript at 15, 55. In the ALJ’s written decision, he initially noted that the alleged onset date had been amended to October 25, 2016, see Transcript at 15, but then repeatedly noted that the alleged onset date is April 24, 2014, see Transcript at 16, 18, 34. In Williams’ brief, she too noted that the alleged onset date is April 24, 2014. See Docket Entry 18 at CM/ECF 1, 5. Because the issue of reopening her prior claim for benefits was not addressed during the administrative proceeding, the Court overlooks the aforementioned references to April 24, 2014, as the alleged onset date and finds that the alleged onset date is October 25, 2016.

3 The parties agree that Williams was insured for purposes of disability insurance benefits through December 31, 2019. Thus, the relevant period for her claim is from October 25, 2016, i.e., the amended alleged onset date, through December 31, 2019, i.e., the date last insured. In addressing Williams’ claim, the ALJ considered evidence from before the relevant period. The Court will do likewise but will do so only briefly in order to place Williams’ condition in an historical context. In addition, the Court will limit its recital of the evidence to that which is relevant to her assertion of severe pain, which forms the basis of her challenge to the ALJ’s findings. Between July of 2013 and the amended alleged onset date, Williams sought medical attention on numerous occasions for the pain in her neck,

shoulders, and back.4 Her pain was aggravated by movement but relieved with rest, changing positions, and medication. Her gait and station were typically normal. She received epidural steroid injections, see Transcript

at 479, and underwent an anterior cervical discectomy and fusion at C5-C6 in April of 2014, see Transcript at 432-433.5 She was prescribed pain medication that included Tramadol, Flexeril, and Cymbalta, and she reported some benefit from Tramadol.

A typical progress note during the period between July of 2013 and the amended alleged onset date is one from January 13, 2016. See Transcript at 495-499. In the note, Williams’ history of present illness was

recorded to be as follows:

4 See e.g., Transcript at 587-589 (07/24/2013), 477-478 (11/08/2013), 479 (12/19/2013), 639-642 (01/27/2014), 801-804 (02/12/2014), 799-800 (03/05/2014), 790-792 (05/13/2014), 623-626 (05/23/2014), 787-789 (06/17/2014), 782-785 (09/23/2014), 777-781 (12/10/2014), 480-484 (07/02/2015), 485-489 (07/29/2015), 490-494 (10/21/2015), 612-614 (10/09/2015), 608-611 (12/28/2015), 772-776 (03/31/2015), 767-771 (05/05/2015), 495-499 (01/13/2016), 500-504 (02/09/2016). The recitals of dates in this Memorandum Opinion and Order are not intended to be complete catalogs of every presentation Williams made for, or testing in connection with, her complaints of pain in her neck, shoulders, and back.

5 The anterior cervical discectomy and fusion, sometimes noted as an “ACDF,” proved largely successful as the results of subsequent testing were typically within normal limits, and she reported improvement. See Transcript at 790-792, 787-789, 462- 465, 467. The record also indicates that during the period, Williams underwent breast reduction surgery in an attempt to relieve her back pain. See Transcript at 62, 1248. History of present illness ... The patient is a 37 female who presents for a recheck of low back pain. The onset of the low back pain has been gradual and has been occurring in a persistent pattern for 4 years. The course has been increasing. The low back pain is described as a mild dull aching. The low back pain is described as being in the lower back. The pain radiates to the lateral aspect of right leg and right foot. The back pain is aggravated by straining at stool, twisting, lifting, sitting, standing and walking. The back pain is relieved by bedrest, change in position and medication.

Additional reasons for visit:

Recheck of Thoracic spine intake is described as the following: The pain is located in the upper back and in the mid back. The pain radiates to the left shoulder, left arm, right shoulder, and right arm. The patient describes the pain as throbbing ... The symptoms occur constantly. The episodes occur daily. Symptoms are exacerbated by lifting and bending. Symptoms are relieved by rest and opioid analgesics.

Recheck of Neck pain is described as the following: The onset of the neck pain has been gradual and has been occurring in an intermittent pattern for 1 year. The course has been constant. The neck pain is described as mild. Note for “Neck pain”: pain radiates into bilat hands and causes numbness and tingling which comes and goes.

See Transcript at 495. Williams rated her pain level as four on a ten point scale. She had normal ambulation and did not require an assistive device to walk. A physician’s assistant diagnosed, in part, neck pain, low back pain, and cervical disease. Medication was prescribed, and Williams was encouraged to re-establish care at a pain management clinic. Williams also underwent extensive medical testing of her neck, shoulders, and back between July of 2013 and the amended alleged onset

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