United States District Court, E.D. Arkansas, Jonesboro Division
ORDER AFFIRMING THE COMMISSIONER
Taylor applied for social security disability benefits with
an amended alleged disability onset date of February 21,
2014. (R. at 57). The administrative law judge (ALJ) held a
hearing, after which he denied the applications. (R. at
45-46). The Appeals Council denied review. (R. at 1). Mr.
Taylor has requested judicial review, and the parties have
consented to the jurisdiction of the magistrate judge.
(Docket entry #4)
The Commissioner's Decision
found that Mr. Taylor had the following severe impairments:
degenerative disk disease of the lumbar spine, osteoarthritis
of the left knee, history of supraventricular tachycardia
status post ablation, essential hypertension, morbid obesity,
and generalized anxiety disorder. (R. at 29). The ALJ further
found that Mr. Taylor had the residual functional capacity
(RFC) to perform light work except that he would be limited
to only occasional stooping kneeling, crouching, and
crawling; and would be limited to work where interpersonal
contact is incidental to the work performed, the complexity
of tasks is learned and performed by rote with few variables
and little judgment, and the supervision is simple, direct,
and concrete. (R. at 31). This RFC precluded Mr. Taylor's
past relevant work. (R. at 44). A vocational expert (VE)
testified that Mr. Taylor's RFC would allow the
performance of other jobs, however, such as sub-assembler or
marking clerk. (R. at 45). The ALJ held, therefore, that Mr.
Taylor was not disabled. (R. at 45-46).
appeal, the Court's task is to review the
Commissioner's decision for legal error and assure that
the decision is supported by substantial evidence on the
record as a whole. Brown v. Colvin, 825 F.3d 936,
939 (8th Cir. 2016) (citing Halverson v. Astrue, 600
F.3d 922, 929 (8th Cir. 2010)). Substantial evidence in this
context means enough evidence that “a reasonable mind
would find it adequate to support [the] conclusion.”
Halverson, 600 F.3d at 929. The Court will not
reverse the Commissioner's decision, however, solely
because there is evidence to support a conclusion different
from that reached by the Commissioner. Pelkey v.
Barnhart, 433 F.3d 575, 578 (8th Cir. 2006).
appeal, Mr. Taylor challenges the ALJ's assessment of his
credibility and the ALJ's finding that he could perform a
reduced range of light work.
found that Mr. Taylor's allegations were not entirely
credible. Mr. Taylor objects to this finding, arguing that
the ALJ misstated several medical findings and incorrectly
determined that his condition had improved.
defer to an ALJ's credibility determination where it is
supported with good reasons and by substantial evidence.
Turpin v. Colvin, 750 F.3d 989, 993 (8th Cir. 2014).
In assessing credibility, the ALJ must consider many factors,
including: the claimant's daily activities; the duration
and intensity of the pain; precipitating and aggravating
factors; the dosage, effectiveness and side-effects of
medication; and functional restrictions; work history.
Renstrom v. Astrue, 680 F.3d 1057, 1066 (8th Cir.
2012) (citing Polaski v. Heckler, 739 F.2d 1320,
1322 (8th Cir. 1984)). The ALJ is not required to
specifically address each Polaski factor.
Strongson v. Barnhart, 361 F.3d 1066, 1072 (8th Cir.
2004). Of course, “an ALJ may not discount a
claimant's subjective complaints solely because the
objective medical evidence does not fully support
them.” Wiese v. Astrue, 552 F.3d 728, 733 (8th
Cir.2009). The ALJ gave good reasons for discounting the
credibility of Mr. Taylor's subjective complaints.
the specific findings that Mr. Taylor objects to are really
not findings at all, but rather, summaries of his medical
records. For instance, he objects to the ALJ's statement
that he was “no longer experiencing chest discomfort
and had not been experiencing lightheadedness, drowsiness,
palpitations, increased peripheral edema, or increased
abdominal growth . . . [and] . . . was diagnosed with
hypertension, chest pain and lightheadedness-resolved,
palpitations, likely associated with atrial tachycardia, and
abnormal electrocardiogram.” (R. at 33). This
recitation is quoted, almost verbatim, from Mr. Taylor's
medical records. (R. at 307, 309). The ALJ went on to
summarize Mr. Taylor's medical records, including those
showing that his symptoms had returned. (R. at 33-43). To the
extent Mr. Taylor objects to these summaries, he is objecting
to the medical records themselves.
Taylor also points to records from June and July of 2017,
arguing that his symptoms were worse than characterized by
the ALJ. (R. at 9-22). As the Appeals Council noted, the ALJ
did not mischaracterize Mr. Taylor's reported symptoms
from the summer of 2017 because the ALJ did not consider, and
could not have considered, records created after he
rendered his decision. (R. at 2).
fact, Mr. Taylor's only substantive objection in this
appeal is to the ALJ's summary of his medical records.
After a review of the medical records, the Court concludes
that the ALJ accurately summarized Mr. Taylor's medical
relied, in part, on Mr. Taylor's daily activities in
finding that subjective complaints were not entirely
credible. Mr. Taylor testified that he cared for his wife,
including taking her to daily wound-care appointments. (R. at
67-68). He reported doing laundry, ironing, and washing. (R.
at 252). Although Mr. Taylor did not do yard work, this was
because the housing authority assumed responsibility yard
maintenance. (R. at 253). The ALJ's credibility
determination is supported by substantial evidence on the
record as a whole.