Woods v. Commissioner of Social Security

Filing 17

JUDGMENT in favor of Stephanie Woods against Commissioner of Social Security. The case is REMANDED for further proceedings. CASE CLOSED. Signed by Magistrate Judge Jane M. Virden on 10/20/16. (ncb)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF MISSISSIPPI
OXFORD DIVISION
STEPHANIE WOODS

PLAINTIFF

V.

NO. 3:16CV00044-JMV

COMMISSIONER OF SOCIAL SECURITY

DEFENDANT

FINAL JUDGMENT
This cause is before the court on Plaintiff’s complaint for judicial review of an
unfavorable final decision of the Commissioner of the Social Security Administration
denying claims for a period of disability and disability insurance benefits and supplemental
security income benefits. The parties have consented to entry of final judgment by the
United States Magistrate Judge under the provisions of 28 U.S.C. § 636(c), with any appeal
to the Court of Appeals for the Fifth Circuit. The court, having reviewed the administrative
record, the briefs of the parties, and the applicable law and having heard oral argument,
finds as follows, to-wit:
Consistent with the court’s ruling from the bench during oral argument, the court
finds the ALJ’s RFC determination is not supported by substantial evidence in the record.
First, the ALJ failed to give adequate consideration to the claimant’s carpal tunnel
syndrome (“CTS”). Indeed, diagnostic testing showed the claimant’s CTS was moderate to
severe. And, while medical examinations indicated the claimant’s CTS was controlled with

medication and wrist splints,1 the RFC found by the ALJ does not account for the
claimant’s need to wear the wrist splints.2
Second, the RFC found by the ALJ does not include a limitation on repetitive
reaching, handling, or fingering. The claimant’s treating physician and Nurse Barnette both
opined the claimant had “significant limitations in doing repetitive reaching, handling, or
fingering”; nevertheless, the ALJ gave no explanation for effectively rejecting these
opinions, as they were not incorporated in the RFC found by the ALJ. This error by the
ALJ was not harmless because the jobs proffered by the vocational expert are designated in
the DOT as involving “REPETITIVE or short cycle work.” Accordingly, the VE should
have been made aware of any limitation against repetitive work.
Third, the Court is not convinced there is support for the ALJ’s finding the claimant
could occasionally lift 20 pounds. Both Dr. Adams and Dr. Riddell opined the claimant
could lift no more than 10 pounds occasionally. And, to the extent the ALJ relied on the
opinion of Nurse Barnette, the ALJ failed to give good reasons for giving less weight to the
opinions of Dr. Adams and Dr. Riddell in this regard. Fourth and final, the ALJ failed to
consider the claimant’s reaching limitation. Dr. Adams limited the claimant to only
occasional reaching in all directions. The ALJ does not discuss this limitation and gives no
explanation for effectively rejecting it.

1

The court notes that Dr. Adams was under the impression the claimant never underwent any diagnostic
testing for CTS despite the existence in the record of a nerve conduction study performed in 2006.
2

It is not apparent from the record that the claimant would have sufficient range of motion of her wrists
to perform repetitive and frequent manipulative work while wearing wrist splints.

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On remand, the ALJ shall reconsider the claimant’s RFC based on all the relevant
evidence in the record and obtain supplemental vocational expert testimony, if necessary.
The ALJ may conduct any additional proceedings not inconsistent with this Court’s order.
IT IS, THEREFORE, ORDERED AND ADJUDGED that this case is
REVERSED and REMANDED for further proceedings.
This, the 20th day of October, 2016.

/s/ Jane M. Virden
U. S. MAGISTRATE JUDGE

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