United States District Court, E.D. Arkansas, Jonesboro Division
THOMAS E. GALCZYNSKI, Plaintiff.
CAROLYN W. COLVIN, Acting Commissioner, Social Security Administration, Defendant.
BETH DEERE, Magistrate Judge.
The following recommended disposition was prepared for U.S. District Judge D.P. Marshall Jr. 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. The objecting party must serve the opposing party with a copy of an objection. Failing to object within 14 days waives the right to appeal questions of fact. If no objections are filed, Judge Marshall may adopt the recommended disposition without independently reviewing all of the record evidence.
Reasoning for Recommended Disposition
Thomas Eugene Galczynski seeks judicial review of the denial of his application for social security disability benefits. In the past, Mr. Galczynski worked as a spray technician for a manufacturer of bathroom fixtures. He stopped working in February 2009 after injuring his arm. In July 2012, he applied for disability benefits. He alleged disability beginning April 2009, but he did not base his claim on the arm injury. Instead, he based his claim on anxiety, panic attacks, and depression. He later amended his alleged onset date to February 18, 2012.
The relevant time period. This case considers whether Mr. Galczynski was disabled from February 18, 2012 - the amended onset date - to March 6, 2014 - the date of the challenged decision. The decision states an erroneous time period - April 15, 2009 - the original onset date - to March 6, 2014 - the date of the decision. The mistake constitutes a scrivener's error that has no bearing on the result. The decision states the amended onset date. The more important consideration is the date insured status expired - December 31, 2013. Mr. Galczynski must prove he was disabled before that date to obtain disability insurance benefits; the date plays no role in the application for supplemental security income.
The Commissioner's decision. The Commissioner's ALJ identified coronary artery disease (status post cardiac stent), irritable bowel syndrome, anxiety disorder, mood disorder, post traumatic stress disorder, and major depressive disorder - as severe impairments. The ALJ determined that Mr. Galczynski could do some light work. Because a vocational expert identified available work, the ALJ determined Mr. Galczynski was not disabled and denied the application.
After the Commissioner's Appeals Council denied a request for review,  the decision became a final decision for judicial review. Mr. Galczynski filed this case to challenge the decision. The recommended disposition explains why the court should affirm the decision.
Galczynski's allegations. Mr. Galcyznski challenges the evaluation of his credibility. He argues that the ALJ ignored evidence favoring his application. He maintains that his treating physician's medical statement deserved more weight. He further argues that the hypothetical question omitted some of his limitations. For these reasons, he contends, substantial evidence does not support the decision.
Applicable legal principles. In reviewing the denial of an application for disability benefits, the court must determine whether substantial evidence supports the decision and whether the ALJ made a legal error. For substantial evidence to exist, a reasonable mind must accept the evidence as adequate to show that Mr. Galczynski could do some light work.
"Light work involves lifting no more than 20 pounds at a time with frequent lifting or carrying of objects weighing up to 10 pounds." The ALJ placed the following limitations on Mr. Galczynski's ability to perform light work:
(1) no contact with the general public,
(2) incidental interpersonal contact,
(3) one-to-two step tasks that can be learned and ...