Lane v. Social Security Administration Commissioner
2:14-cv-02188
| W.D. Ark. | Dec 30, 2015Background
- Plaintiff Janelle Lynn Lane (b. 1964) applied for SSI on Dec 7, 2011, alleging disabling diabetes, degenerative disc disease, neuropathy, depression, and related symptoms; prior DIB application in 2009 was denied and not at issue.
- Administrative hearing held Mar 12, 2013; ALJ found severe impairments: obesity, diabetes, cervical/lumbar osteoarthritis, factitious disorder NOS, and personality traits; denied disability.
- ALJ assessed an RFC for light work limited to simple, routine, repetitive tasks with few workplace changes and only incidental contact with others.
- At step five, vocational expert testified jobs exist in significant numbers (representative light unskilled and production/assembly jobs).
- Plaintiff appealed, arguing the ALJ erred by (1) failing to find peripheral neuropathy a severe impairment at step two, and (2) omitting postural limitations (e.g., stooping) from the RFC.
- Magistrate Judge Ford affirmed the ALJ, concluding substantial evidence supported the non-severity finding for neuropathy and the RFC assessment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether peripheral neuropathy is a severe impairment at step two | Lane: neuropathy diagnosed and causes pain/functional limits | Gov't: record lacks objective testing and most exams/notes show normal neuro findings | Court: Not severe — diagnosis not supported by objective tests or consistent exam findings; ALJ supported by substantial evidence |
| Whether RFC should include postural limitations (stooping) due to back disease | Lane: degenerative disc disease, reduced ROM, pain, narcotic use warrant postural limits | Gov't: imaging and exams show mild findings; nonexamining reviewers found light RFC without postural limits; conservative treatment and inconsistent complaints undermine greater limits | Court: RFC for light work without additional postural limits supported by medical evidence, consultative exam, state agency opinions, and credibility analysis |
Key Cases Cited
- Vossen v. Astrue, 612 F.3d 1011 (8th Cir. 2010) (substantial-evidence standard governs review)
- Miller v. Colvin, 784 F.3d 472 (8th Cir. 2015) (court must affirm if evidence supports ALJ even when contrary evidence exists)
- Pearsall v. Massanari, 274 F.3d 1211 (8th Cir. 2001) (claimant bears burden to prove disability lasting 12 months)
- Simmons v. Massanari, 264 F.3d 751 (8th Cir. 2001) (step-two severity analysis explained)
- Lauer v. Apfel, 245 F.3d 700 (8th Cir. 2001) (RFC is a medical question and must be supported by medical evidence)