Frazier v. Social Security Administration Commissioner
5:24-cv-05186
W.D. Ark.Mar 11, 2025Background
- Clarence Edward Frazier, II applied for Disability Insurance Benefits (DIB) alleging disability since February 18, 2022 due to multiple physical and mental impairments.
- Plaintiff's application was denied at the administrative level after a hearing before an ALJ, who found several severe impairments but concluded Frazier could perform sedentary work with limitations.
- The ALJ’s RFC determination was partially based on non-examining medical consultants' opinions, potentially without the benefit of all relevant, updated medical records, especially regarding spinal surgery in July 2023.
- Frazier appealed the denial, but the Appeals Council declined review, so he filed this federal action.
- The district court reviewed whether substantial evidence supported the Commissioner’s decision and if the correct legal standards were applied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of ALJ's RFC finding | ALJ failed to consider updated medical records, esp. post-surgery evidence | RFC finding supported by substantial evidence including prior consultant opinions | ALJ erred; remand to more fully develop the record |
| Reliance on non-examining opinions | Non-examining opinions lacked access to key records and were outdated | These opinions are entitled to weight | Not clear opinions reflected reality; remand |
| Consideration of all impairments | ALJ did not adequately incorporate all limitations | All severe impairments were considered | ALJ must reconsider RFC with more complete record |
| Substantial evidence standard | Decision not supported due to incomplete record | Substantial evidence supports denial | Decision not supported; reversed and remanded |
Key Cases Cited
- Brown v. Colvin, 825 F.3d 936 (8th Cir. 2016) (scope of review is de novo for legal error and substantial evidence for findings of fact)
- Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (defines "substantial evidence" standard)
- Lawson v. Colvin, 807 F.3d 962 (8th Cir. 2015) (affirmance required if substantial evidence exists)
- Miller v. Colvin, 784 F.3d 472 (8th Cir. 2015) (may not reverse even if court would decide differently if evidence supports ALJ)
- Pearsall v. Massanari, 274 F.3d 1211 (8th Cir. 2001) (claimant’s burden to prove lasting disability)
- Guilliams v. Barnhart, 393 F.3d 798 (8th Cir. 2005) (RFC assessment considers all record evidence)
- Eichelberger v. Barnhart, 390 F.3d 584 (8th Cir. 2004) (pain is factored into RFC assessment)
- Lauer v. Apfel, 245 F.3d 700 (8th Cir. 2001) (RFC is a medical question)
- Lewis v. Barnhart, 353 F.3d 642 (8th Cir. 2003) (ALJ must specifically set forth RFC limitations)