Woodell v. Social Security Administration

CourtDistrict Court, E.D. Arkansas
DecidedApril 29, 2025
Docket4:24-cv-00502
StatusUnknown

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

Opinion

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

LAWRENCE WOODELL, JR. PLAINTIFF

V. Case No. 4:24-CV-00502-LPR-BBM

LELAND DUDEK, Acting Commissioner, Social Security Administration1 DEFENDANT

RECOMMENDED DISPOSITION

This Recommended Disposition (“Recommendation”) has been sent to United States District Judge Lee P. Rudofsky. 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 Rudofsky 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 16, 2020, Plaintiff Lawrence Woodell, Jr. (“Woodell”) filed a Title II application with the Social Security Administration (“SSA”) for a period of disability and disability insurance benefits. (Tr. at 14). On the same day, he protectively filed a Title XVI application for supplemental security income. Id. In the applications, he alleged disability

1 Leland Dudek serves currently as Acting Commissioner of the Social Security Administration. Pursuant to Federal Rule of Civil Procedure 25(d), Acting Commissioner Dudek (“the Commissioner”) is automatically substituted as the Defendant. beginning on May 1, 2020. Id. The applications were denied initially and on reconsideration. Id. After conducting a hearing, an Administrative Law Judge (“ALJ”) denied

Woodell’s applications by written decision, dated July 19, 2023. (Tr. at 14–28). The Appeals Council denied Woodell’s request for review of the ALJ’s decision on April 26, 2024. (Tr. at 1–6). The ALJ’s decision now stands as the final decision of the Commissioner, and Woodell has requested judicial review. For the reasons stated below, the Court recommends that the Commissioner’s decision be affirmed.

II. THE COMMISSIONER’S DECISION

The ALJ found that Woodell has not engaged in substantial gainful activity since May 1, 2020—the alleged onset date of disability.2 (Tr. at 16). Woodell meets the insured status requirements of the Social Security Act through December 31, 2025. Id. At Step Two, the ALJ determined that Woodell has the following severe impairments: coronary artery disease with stent placement and atherosclerotic heart disease, obesity, chronic obstructive pulmonary disease (COPD)/asthma, degenerative disc disease of the lumbar spine with grade one anterolisthesis, right chondromalacia with degenerative meniscal tear and degenerative joint changes and knee pain. (Tr. at 17). At Step Three, the ALJ decided that Woodell’s impairments did not meet or equal

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). a Listing.3 (Tr. at 18–19). The ALJ then determined that Woodell has the residual functional capacity (“RFC”) to perform work at the light exertional level, with the following additional limitations: (1) can have no more than occasional exposure to dusts,

fumes, smoke, and other pulmonary irritants, and (2) can no more than occasionally climb, stoop, bend, kneel, crouch, and crawl. (Tr. at 19). At Step Four, the ALJ relied upon vocational expert (“VE”) testimony to determine that Woodell could return to performing past relevant work as a laser machine operator. (Tr. at 26). Notwithstanding, the ALJ continued to Step Five to determine, based on VE

testimony and Woodell’s age, education, work experience and RFC, that there are jobs in the national economy that Woodell can perform. (Tr. at 26–28). Therefore, the ALJ concluded that Woodell 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

3 20 C.F.R. Part 404, Subpt. P, Appendix 1 (20 C.F.R. §§ 404,1520(d), 404.1525, 404.1526, 416.920(d), 416.925, and 416.926). Additionally:

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.’ . . . 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 whether he actually can perform his own prior work or other work.

Sullivan v. Zebley, 493 U.S. 521, 532 (1990) (emphasis in original) (internal citations omitted). 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. Woodell’s Arguments on Appeal

Woodell contends that the evidence supporting the ALJ’s decision is less than substantial. Specifically, Woodell argues that: (1) the RFC for light work with postural limitations did not fully account for his alleged difficulty with walking and standing, (Doc.

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