United States District Court, E.D. Arkansas, Jonesboro Division
Christopher Layne, applied for disability income benefits and
supplemental security income benefits on June 19, 2014,
alleging his disability began on May 1, 2012. (Tr.
at 11). His claims were denied initially and upon
reconsideration. Id. After conducting a hearing, the
Administrative Law Judge (“AALJ") denied
Layne's application on November 4, 2015. (Tr. at 23). The
Appeals Council denied his request for review. (Tr. at 1).
The ALJ's decision now stands as the final decision of
the Commissioner, and Layne has requested judicial review.
reasons stated below, the Court affirms the decision of the
The Commissioner's Decision:
found that Layne had not engaged in substantial gainful
activity since the alleged onset date of May 1, 2012 (Tr. at
13). At Step Two of the five-step analysis, the ALJ found
that Layne has the following severe impairments: degenerative
disc disease of the lumbar spine and status post discectomy;
obstructive sleep apnea; hypertension; obesity; generalized
anxiety disorder; depression; and Haglund's deformity.
(Tr. at 14).
finding that Layne's impairments did not meet or equal a
listed impairment (Tr. at 14), the ALJ determined that Layne
had the residual functional capacity (“RFC”) to
perform the full range of sedentary work, except that: (1) he
cannot climb ladders, ropes, or scaffolds; (2) the work must
not require balancing duties; (3) he can only occasionally
climb ramps and stairs; (4) he can only occasionally stoop,
kneel, crouch, and crawl; (5) he must be able to access a
work station area with a cane as needed; (6) he cannot be
exposed to hazards in the work place; (7) he must avoid
exposure to unprotected heights; (8) the work must not
require any left lower extremity foot control operation; (9)
the work must not require contact with the general public;
(10) interpersonal contact must be no more than incidental to
the work performed; (11) the supervision required is simple,
direct, and concrete; and (12) the work must be limited to
SVP 1 or 2 jobs that can be learned in thirty
days. (Tr. at 16-17).
the ALJ found that Layne was not capable of performing any
past relevant work. (Tr. at 21). At Step Five, the ALJ relied
on the testimony of a Vocational Expert (“VE”) to
find that, based on Layne's age, education, work
experience and RFC, jobs existed in significant numbers in
the national economy that he could perform at the sedentary
level with the added limitations, specifically, lampshade
production assembler and general office clerk (document
preparer). (Tr. at 22-23). Based on that Step Five
determination, the ALJ held that Layne was not disabled.
Standard of Review
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 Asubstantial evidence" is that which a reasonable
mind might accept as adequate to support a conclusion,
Asubstantial 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, Amerely
because substantial evidence would have supported an opposite
Reed v. Barnhart, 399 F.3d 917, 920 (8th Cir. 2005)
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 ...