Hearod v. Dudek
4:24-cv-00077
E.D. Mo.Mar 11, 2025Background
- Kathleen Hearod applied for Social Security disability benefits at age 48, alleging disability due to traumatic brain injury and cervical spine issues following a 2021 fall.
- The Commissioner denied her claim for disability prior to her 50th birthday but found her disabled as of turning 50, per Medical-Vocational Guidelines.
- Hearod represented herself pro se at the district court review stage and submitted supplemental lay statements from family and caregivers regarding her daily limitations.
- The ALJ concluded she could perform sedentary, unskilled work prior to age 50, based on medical evidence and vocational expert testimony.
- The district court's review focused on whether substantial evidence supported the ALJ's findings and whether due process required further development of the record.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Disability finding prior to age 50 | ALJ ignored evidence of traumatic brain injury and its severity | ALJ properly evaluated evidence; impairments did not meet listed severity | For Defendant |
| Reliance on vocational expert (VE) testimony | VE testimony was insufficient and did not support denial | VE testimony valid, based on supported RFC | For Defendant |
| Development of the administrative record | ALJ failed to seek additional lay witness statements | No duty to seek cumulative, non-medical evidence | For Defendant |
| Damages for mental anguish over denied benefits | Sought $100,000 for mental anguish due to benefits denial | Court lacks authority to award such damages | For Defendant; court lacks authority |
Key Cases Cited
- Johnson v. Astrue, 628 F.3d 991 (8th Cir. 2011) (articulates the substantial evidence standard for review of Social Security determinations)
- Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (clarifies the low threshold for substantial evidence in Social Security cases)
- Chaney v. Colvin, 812 F.3d 672 (8th Cir. 2016) (explains deference to Commissioner's findings when evidence is susceptible to multiple interpretations)
- Schweiker v. Chilicky, 487 U.S. 412 (1988) (Social Security Act does not provide for money damages for wrongful denial of benefits)
- Phillips v. Astrue, 671 F.3d 699 (8th Cir. 2012) (ALJ must apply Medical-Vocational Guidelines when appropriate)