Holstein v. Dudek (CONSENT)
2:24-cv-00115
M.D. Ala.Mar 11, 2025Background
- Plaintiff Amber H., a 35-year-old with a high school education and no past relevant work, applied for Supplemental Security Income (SSI) alleging disability due to bipolar disorder, manic depression, and severe anxiety.
- The Social Security Administration denied her application; subsequent appeals were unsuccessful, making the ALJ's decision the Commissioner's final decision.
- Plaintiff sought review in federal court, arguing the ALJ's residual functional capacity (RFC) assessment was flawed.
- The ALJ determined plaintiff had severe impairments (obesity, anxiety, major depressive disorder) but did not meet or equal a listed impairment.
- The ALJ found plaintiff could perform certain jobs (e.g., floor waxer, kitchen helper, meat clerk) existing in significant numbers in the national economy.
- The parties cross-moved for summary judgment, with the magistrate judge ultimately affirming the Commissioner's decision and denying plaintiff's.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| RFC exclusion of “short” from instructions limitation | RFC should have limited to "short, simple instructions," aligning with persuasive medical opinions | The ALJ adequately explained reliance on reconsideration-level opinion lacking this restriction | ALJ’s failure to explain omission was error but harmless as sufficient jobs exist at restricted reasoning level |
| Exclusion of arithmetic limitation in RFC | ALJ should have found plaintiff unable to do even simple arithmetic based on medical opinion | Evidence showed plaintiff could perform basic math; Nurse Practitioner’s opinion did not contradict this | ALJ’s determination supported; no conflict in opinion—no reversible error |
Key Cases Cited
- Dyer v. Barnhart, 395 F.3d 1206 (11th Cir. 2005) (substantial evidence standard for judicial review of Social Security disability decisions)
- Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155 (11th Cir. 2004) (definition and application of substantial evidence review in SSI cases)
- Ingram v. Comm’r of Soc. Sec. Admin., 496 F.3d 1253 (11th Cir. 2007) (court reviews conclusions of law de novo, not entitled to same deference as factual findings)
- Hale v. Bowen, 831 F.2d 1007 (11th Cir. 1987) (burden shifts to Commissioner in Step 5 of disability evaluation)
- Allen v. Bowen, 816 F.2d 600 (11th Cir. 1987) (sufficient number of national jobs satisfies Step 5 burden)