Smallwood v. Social Security Administration
6:24-cv-00121
| E.D. Okla. | Feb 12, 2025Background
- Charles J. Smallwood applied for Social Security disability insurance benefits and supplemental security income, alleging disability from September 1, 2010, primarily due to physical and mental impairments.
- Claimant has a high school education and prior work as a gate guard, correction officer, technician, and others.
- His claim has continuously been denied across multiple rounds of administrative hearings and court remands, with the most recent ALJ decision in February 2022 finding him not disabled at step five.
- Severe impairments found included type II diabetes, significant knee issues, back disorders, and several serious mental health conditions (bipolar disorder, PTSD, etc.).
- The ALJ credited but did not wholly adopt state agency psychologists' opinions regarding moderate limitations in following detailed instructions, instead limiting claimant to simple routine tasks without adequate explanation.
- The Magistrate Judge recommends reversal and remand due to the ALJ’s failure to resolve material inconsistencies per SSR 96-8p, specifically regarding the claimant’s ability to carry out detailed instructions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ properly assess claimant’s RFC under SSR 96-8p? | ALJ failed to explain why limitations on following detailed instructions (supported by medical evidence) were not reflected in the RFC. | ALJ’s findings were supported by substantial evidence and incorporated credible medical opinions. | ALJ did not comply with SSR 96-8p; reversal and remand required. |
| Did the ALJ adequately explain the weight given to medical opinions? | ALJ assigned partial weight but did not resolve material inconsistencies or explain omissions from RFC. | ALJ provided sufficient rationale for weight assigned to opinions. | ALJ’s explanation was insufficient; failure to explain omission requires remand. |
| Was the step five finding supported by substantial evidence? | Step five jobs identified require following detailed instructions inconsistent with the RFC limitations found. | Jobs identified are within claimant’s residual functional capacity. | Step five finding not supported; ALJ must reconsider available jobs in light of complete limitations. |
| Was there compliance with prior remand instructions? | ALJ ignored binding rulings and did not resolve key limitations as required by prior remand. | ALJ followed proper legal standards and prior instructions. | Court found noncompliance with SSR 96-8p and reversed for further proceedings. |
Key Cases Cited
- Richardson v. Perales, 402 U.S. 389 (support for substantial evidence standard)
- Consolidated Edison Co. v. NLRB, 305 U.S. 197 (definition of substantial evidence)
- Universal Camera Corp. v. NLRB, 340 U.S. 474 (court must consider all evidence, including detracting evidence)
- Clifton v. Chater, 79 F.3d 1007 (substantial evidence review in Social Security cases)
- Casias v. Secretary of Health & Human Services, 933 F.2d 799 (court may not reweigh evidence)
- Hawkins v. Chater, 113 F.3d 1162 (scope of judicial review under § 405(g))