Williams v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedJune 25, 2024
Docket4:23-cv-01021
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. 2024).

Opinion

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

SUSAN RAYE WILLIAMS PLAINTIFF

V. NO. 4:23CV01021-JM-PSH

MARTIN O’MALLEY, COMMISSIONER of the SOCIAL SECURITY ADMINISTRATION DEFENDANT

RECOMMENDED DISPOSITION

This Recommended Disposition (“Recommendation”) has been sent to United States District Judge James M. Moody, Jr. Either party may file written objections to this Recommendation. If objections are filed, they should be specific and should include the factual or legal basis for the objection. To be considered, objections must be received in the office of the Court Clerk within 14 days of this Recommendation. If no objections are filed, Judge Moody can adopt this Recommendation without independently reviewing the record. By not objecting, parties may also waive the right to appeal questions of fact. I. Introduction:

Plaintiff, Susan Raye Williams, filed an application for Title II disability and disability insurance benefits on August 20, 2020. (Tr. at 17). She also filed an application for Title XVI supplemental security income on February 18, 2022. Id. In

1 both applications, Ms. Williams alleged disability beginning on July 15, 2020. Id. The applications were denied initially and upon reconsideration. Id. After

conducting a hearing on April 13, 2022, an Administrative Law Judge (AALJ@) denied Ms. Williams’s applications. (Tr. at 17-34). On August 23, 2023, the Appeals Council denied Ms. Williams’s request for review of the hearing decision. (Tr. at 1-

6). This decision stands as the final decision of the Commissioner, and Ms. Williams has requested judicial review. For the reasons stated below, this Court should affirm the ALJ’s decision and enter judgment for Defendant.

II. The Commissioner=s Decision: The ALJ found that Ms. Williams meets the insured status requirement of the Social Security Act through September 30, 2025. (Tr. at 20). The ALJ next found

that Ms. Williams had not engaged in substantial gainful activity since the alleged onset date of July 15, 2020. Id. At Step Two, the ALJ found that Ms. Williams had the following severe impairments: spine disorder, obesity, anxiety, and depression. Id.

After finding that Ms. Williams’s impairments did not meet or equal a Listing,1 the ALJ determined that Ms. Williams had the residual functional capacity

1 20 C.F.R. Part 404, Subpart P, Appendix 1.

2 (“RFC”) to perform work at the sedentary exertional level, with the following additional limitations: (1) she can no more than occasionally climb, balance, crawl

kneel, stoop, and crouch; (2) she can no more than occasionally reach overhead bilaterally; (3) she is limited to simple, routine, tasks; and (4) she can respond to supervision that is simple, direct, and concrete. (Tr. at 22).

The ALJ determined that Ms. Williams was unable to perform any past relevant work. (Tr. at 27). At Step Five, the ALJ relied on the testimony of a Vocational Expert (VE) to find that, considering Ms. Williams’s age, education, work experience, and RFC, jobs existed in significant numbers in the national

economy that she could perform, such as pastry trimmer, document clerk, and addressing clerk. (Tr. at 28-29). Thus, the ALJ found that Ms. Williams 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

3 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.”

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. It is not the task of this Court to review the evidence and make an independent

decision. Neither is it to reverse the decision of the ALJ because there is evidence in the record which contradicts his findings. The test is whether there is substantial evidence in the record as a whole which supports the decision of the ALJ. Miller,

784 F.3d at 477.

4 B. Ms. Williams’s Arguments on Appeal Ms. Williams contends that the evidence supporting the ALJ=s decision to

deny benefits is less than substantial. She argues that: (1) the ALJ failed to fully develop the record; (2) the ALJ erred at Step Two; (3) the ALJ failed to properly analyze Ms. Williams’s subjective complaints; and (4) the RFC did not incorporate

all of Ms. Williams’s credible limitations. The ALJ thoroughly discussed Ms. Williams’s medical conditions. He noted her complaints of back pain, which were supported by objective findings showing thoracic disc bulges and scoliosis, as well as lumbosacral spondylosis and foraminal

narrowing. (Tr. at 335, 468-472, 582-599). A consultative examiner saw Ms. Williams in August 2022. He found normal blood pressure, normal range of motion in her spine and lower extremities, normal bilateral straight-leg raise, and no signs

of muscle weakness. (Tr. at 876-877). Ms. Williams could walk without an assistive device and squat and arise from a squatting position. Id. The examiner assessed no exertional or mental limitations.2 Ms. Williams also had anxiety and depression and cardiac complications. In

2 Although she had the opportunity to do so, Ms. Williams’s counsel did not submit any written questions to the examiner. (Tr. at 327). This undermines her contentions that the examiner did not have proper background evidence and that his opinion did not constitute substantial evidence. (Doc. No. 10 at 9).

5 2021 and 2022, Ms. Williams attended counseling and received psychotropic medications for her mental impairments. (Tr. at 655-710). At clinical examinations,

she seemed anxious and depressed and sometimes paced and rocked back and forth, but at various visits to counseling, she generally had normal speech, memory, insight, and judgment. (Tr. at 655-656, 669-690, 701-710). Moreover, Ms.

Williams’s anxiety got worse when her husband got sick, and when she had to care for her elderly father.3 (Tr. at 21-25). Finally, she did not require aggressive care like inpatient psychiatric hospitalization. Ms. Williams’s anxiety contributed to occasional high blood pressure

readings and mild tachycardia, and the ALJ acknowledged this. (Tr. at 22-25, 598- 603, 654-655). Ms.

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Williams v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-social-security-administration-ared-2024.