Keith v. Social Security Administration

United States District Court, Eastern District of Arkansas, Delta Division · March 24, 2025 · No. 2:24-cv-00176

Summary

This document is a Recommended Disposition issued by a United States Magistrate Judge in the Eastern District of Arkansas regarding a Social Security disability appeal. The magistrate judge found that the Administrative Law Judge failed to adequately evaluate conflicting medical evidence concerning the plaintiff's need for a cane or assistive device. Consequently, the court recommends reversing the Commissioner's denial of benefits and remanding the case for further administrative review.

Court
United States District Court, Eastern District of Arkansas, Delta Division
Jurisdiction
United States District Court, Eastern District of Arkansas
Decision date
March 24, 2025
Docket number
2:24-cv-00176
Procedural posture
Plaintiff seeks judicial review of an ALJ decision denying SSDI benefits; the court issued a recommended disposition to reverse and remand.
Standard of review
Substantial evidence standard; the court reviews whether the Commissioner’s decision is supported by substantial evidence on the record as a whole and free of legal error.
Precedential value
nonprecedential
Parties
Pauline Keith v. Commissioner of Social Security Administration
Disposition
reversed_and_remanded

Topics

judicial review of agency actionadministrative lawcivil procedure

Practice areas

administrative lawdisability law

Questions Presented

  1. Whether the ALJ’s decision denying benefits is supported by substantial evidence
  2. Whether the ALJ properly considered Keith’s need for a cane or assistive device

Holdings

  1. The ALJ’s decision is not supported by substantial evidence and is reversed.
  2. The ALJ failed to properly consider and discuss the necessity of a cane; the decision is reversed and remanded for further administrative review.

Key quotations

The Court’s function on review is to determine whether the Commissioner’s decision is supported by substantial evidence on the record as a whole and whether it is based on legal error. (at 477)
An ALJ must give good and clear reasons about the persuasiveness of medical opinions. His reasons here are muddled with respect to the use of a cane. (at 1154)

Factual background

Keith applied for Title II disability benefits alleging onset of disability on September 27, 2019. She suffers from colon cancer, osteoarthritis, degenerative disc disease, obesity, and neuropathy, resulting in chronic pain, limited mobility, and occasional use of a cane. Medical records show persistent pain, limited range of motion, and recommendations for assistive devices.

Procedural history

Keith applied for SSDI benefits, was denied by the SSA, appealed to an ALJ who affirmed denial, the Appeals Council declined review, and the case was brought to this district court for review.

Remand instructions

The case is remanded for further administrative review, including a proper evaluation of the claimant’s need for a cane or other assistive device.

Court Document

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