United States District Court, E.D. Arkansas, Eastern Division
BETH DEERE, Magistrate Judge.
The following recommended disposition will be sent to U.S. District Judge Susan Webber Wright. A party to this dispute may file written objections to this recommendation. An objection must be specific and state the factual and/or legal basis for the objection. An objection to a factual finding must identify the finding and the evidence supporting the objection. Objections must be filed with the clerk of the court no later than 14 days from the date of this recommendation. 28 U.S.C. § 636(b)(1); FED. R. CIV. P. 72(b). The objecting party must serve the opposing party with a copy of her objections. Failing to object within 14 days waives the right to appeal questions of fact. Griffin v. Mitchell, 31 F.3d 690, 692 (8th Cir. 1994). If no objections are filed, Judge Wilson can adopt the recommended disposition without independently reviewing all of the record evidence.
Report and Recommendation
Plaintiff Catrecia Scaife has appealed the final decision of the Commissioner of the Social Security Administration denying her claim for disability insurance benefits and supplemental security income. 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 the decision is free of legal error. Slusser v. Astrue, 557 F.3d 923, 925 (8th Cir. 2009); Long v. Chater, 108 F.3d 185, 187 (8th Cir. 1997); see also 42 U.S.C. §§ 405(g). Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Richardson v. Perales, 402 U.S. 389, 401 (1971); Reynolds v. Chater, 82 F.3d 254, 257 (8th Cir. 1996). In assessing the substantiality of the evidence, the Court has considered evidence that detracts from the Commissioner's decision as well as evidence that supports it.
The Commissioner's Decision
After conducting an administrative hearing, the Administrative Law Judge (ALJ) concluded that Ms. Scaife had not been under a disability within the meaning of the Social Security Act at any time through August 18, 2011, the date of his decision. ( Id. at 23) On April 8, 2013, the Appeals Council denied Ms. Scaife's request for review of the ALJ's decision, making the ALJ's decision the final decision of the Commissioner. ( Id. at 1-3) Ms. Scaife then filed her complaint initiating this appeal. (Docket #2)
Ms. Scaife was thirty-seven years old at the time of her hearing. (SSA record at 35) She was a high school graduate and had last worked as a certified nursing assistant ("CNA") but quit that job because of her high-risk pregnancy. (SSA record at 36-37) She based her disability applications on back pain, a high-risk pregnancy, depression, anxiety, obesity, and fatigue. (SSA record at 64, 67)
The ALJ found that Ms. Scaife had "severe" impairments: obesity, carpal tunnel syndrome, and degenerative disc disease of the lumbar spine. ( Id. at 16) He found that she did not have an impairment or combination of impairments that met or equaled a Listing. ( Id. at 18) He judged that Ms. Scaife's allegations regarding the intensity, persistence, and limiting effects of her symptoms were not totally credible. ( Id. at 20)
Based on these findings, the ALJ concluded that Ms. Scaife retained the residual functional capacity ("RFC") for sedentary work, but that she was unable to climb ladders, ropes, or scaffolds and should not be exposed to work-place hazards. ( Id. at 18) Additionally, he found that she could perform all other postural activities on an occasional basis, but could not perform rapid, repetitive flexing of the left wrist and would have to avoid concentrated exposure to heat, cold, and pulmonary irritants. ( Id. )
Based on testimony from a vocational expert ("VE"), the ALJ concluded that Ms. Scaife could not perform her past relevant work, but that she could perform other jobs that existed in significant numbers in the national economy. ( Id. at 26-27) Thus, the ALJ concluded that Ms. Scaife was not disabled. ( Id. at 23-24)
Residual Functional Capacity
Ms. Scaife argues that the ALJ erred by finding she had the residual functional capacity ("RFC") to perform a limited range of sedentary work. More specifically, she maintains that the ALJ failed to give proper consideration to her carpal tunnel syndrome and obesity. For the reasons set forth below, substantial evidence supports the ALJ's RFC assessment.
The ALJ must determine a claimant's RFC based on all relevant evidence, including medical records, observations of treating physicians and others, and the claimant's own descriptions of her limitations. Tellez v. Barnhart, 403 F.3d 953, 957 (8th ...