United States District Court, E.D. Arkansas, Jonesboro Division
MEMORANDUM OPINION AND ORDER
JOE J. VOLPE, Magistrate Judge.
Plaintiff, Adrian Lewis, appeals the final decision of the Commissioner of the Social Security Administration (the "Commissioner") denying her claims for supplemental security income ("SSI") benefits under Title XVI of the Social Security Act (the "Act"). For reasons set out below, the decision of the Commissioner is AFFIRMED.
On March 12, 2012, Ms. Lewis protectively filed for SSI benefits due to anxiety, hypertension, PTSD, hypokalemia, lumbago, reactive airway disease, depression, herniated nucleus pulposus, allergic rhinitis, morbid obesity, depression, chronic pain, and arthritis. (Tr. 267) Ms. Lewis's claims were denied initially and upon reconsideration. At Ms. Lewis's request, an Administrative Law Judge ("ALJ") held a hearing on July 16, 2013, where Ms. Lewis appeared pro se. At the hearing, the ALJ heard testimony from Ms. Lewis and a vocational expert ("VE"). (Tr. 1-44) The ALJ issued a decision on November 1, 2013, finding that Ms. Lewis was not disabled under the Act. (Tr. 59-73) The Appeals Council denied Mr. Lewis's request for review, making the ALJ's decision the Commissioner's final decision. (Tr. 79-82)
Ms. Lewis, who was forty-two years old at the time of the hearing, has a high school education and past relevant work as cashier, telemarketer, and cleaner. (Tr. 10, 15, 36)
II. DECISION OF THE ADMINISTRATIVE LAW JUDGE
The ALJ found that Ms. Lewis had not engaged in substantial gainful activity since March 12, 2012, and she had the following severe impairments: degenerative disc disease, obesity, depression, and anxiety. (Tr. 61) However, the ALJ found that Ms. Lewis did not have an impairment or combination of impairments meeting or equaling an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1. (Tr. 62)
According to the ALJ, Ms. Lewis has the residual functional capacity ("RFC") to perform light, unskilled work, except she can only occasionally climb ramps and stairs, but never climb ladders, ropes, or scaffolds. She can occasionally balance, stoop, kneel, crouch, and crawl. She must be able to sit and stand as needed and should have no more than occasional and superficial contact with others. (Tr. 64) The VE testified that Ms. Lewis could do her past relevant work as a cleaner, and that other jobs available with these limitations were mail room clerk, copy machine operator, and small products assembler. (Tr. 37-38) Accordingly, the ALJ determined that Ms. Lewis could perform a significant number of jobs existing in the national economy, and found that she was not disabled.
A. Standard of Review
In reviewing the Commissioner's decision, this Court must determine whether there is substantial evidence in the record as a whole to support the decision. Substantial evidence is "less than a preponderance, but sufficient for reasonable minds to find it adequate to support the decision."
In reviewing the record as a whole, the Court must consider both evidence that detracts from the Commissioner's decision and evidence that supports the decision; but, the decision cannot be reversed "simply because some evidence may support the opposite conclusion."
B. Ms. Lewis's Argument for Reversal
Ms. Lewis asserts the Commissioner's decision should be reversed because the ALJ (1) erred in the credibility analysis; and (2) failed to ...