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Baldwin v. Berryhill

United States District Court, E.D. Arkansas, Jonesboro Division

December 7, 2017

JESSICA BALDWIN PLAINTIFF
v.
NANCY A. BERRYHILL, Acting Commissioner, Social Security Administration DEFENDANT

          ORDER

         I. Introduction:

         Plaintiff, Jessica Baldwin, applied for disability benefits on December 4, 2013, alleging an onset date of December 28, 2012. (Tr. at 15). Her claims were denied initially and upon reconsideration. Id. After conducting a hearing, the Administrative Law Judge (“ALJ”) denied Baldwin's application. (Tr. at 28). The Appeals Council denied her request for review. (Tr. at 1). The ALJ's decision now stands as the final decision of the Commissioner, and Baldwin has requested judicial review.

         For the reasons stated below, the Court[1] reverses the ALJ's decision and remands for further review.

         II. The Commissioner's Decision:

         The ALJ found that Baldwin had not engaged in substantial gainful activity since the alleged onset date of December 28, 2012. (Tr. at 17). At Step Two, the ALJ found that Baldwin has the following severe impairments: degenerative disc disease of the cervical and lumbar spine, status post bilateral hip replacement, obesity, diabetes, depression, and anxiety. Id.

         After finding that Baldwin's impairments did not meet or equal a listed impairment (Tr. at 21), the ALJ determined that Baldwin had the residual functional capacity (“RFC”) to perform the full range of sedentary work. (Tr. at 22). Next, the ALJ found that Baldwin was unable to perform any past relevant work. (Tr. at 26). Based on Baldwin's age, education, work experience, and RFC, the ALJ relied on Rule 201.28 of the Medical-Vocational Guidelines to find that Baldwin was not disabled.[2] (Tr. at 27).

         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 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, “Amerely because substantial evidence would have supported an opposite decision.”

Reed v. Barnhart, 399 F.3d 917, 920 (8th Cir. 2005) (citations omitted).

         B. Baldwin's Arguments on Appeal

         Baldwin argues that substantial evidence does not support the ALJ's decision to deny benefits. She contends that the RFC was not reflective of her limitations because she could not engage in prolonged sitting and was limited in her ability to reach. She also asserts that the ALJ's credibility analysis was flawed.

         A claimant's RFC represents the most he can do despite the combined effects of all of his credible limitations and must be based on all credible evidence. McCoy v. Astrue, 648 F.3d 605, 614 (8th Cir. 2011). In determining the claimant's [RFC], the ALJ has a duty to establish, by competent medical evidence, the physical and mental activity that the claimant can perform in a work setting, after giving appropriate consideration to all of [his] impairments. Wildman v. Astrue, 596 F.3d 959, 969 (8th Cir. 2010); Ostronski v. ...


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