## Facts

- Virginia Armstrong applied for disability insurance benefits and supplemental security income, alleging disability from bursitis in her left arm, arthritis, dizzy spells, bleeding ulcers, and diabetes.
- Her applications were denied initially and on reconsideration.
- An Administrative Law Judge (ALJ) held a hearing and considered medical records dating back to about 1982, Armstrong’s testimony, and vocational expert testimony.
- The ALJ found Armstrong had several severe impairments but concluded she retained the residual functional capacity (RFC) for sedentary semi-skilled and unskilled work.
- Based on that RFC, the ALJ found Armstrong could perform her prior work as a cashier and therefore was not disabled; the decision became the Secretary’s final decision.
- In federal court, a magistrate judge twice recommended affirmance; Armstrong objected, and the district court conducted de novo review.

## Issues

1. Whether the ALJ properly evaluated Armstrong’s subjective complaints of pain and functional limitation in light of the record.
2. Whether substantial evidence supported the ALJ’s RFC finding and the conclusion that Armstrong could perform her past relevant work as a cashier.

## Decision

- The district court rejected the recommendation to affirm the denial of benefits.
- The court held the ALJ’s denial was not supported by substantial evidence due primarily to an inadequate assessment of Armstrong’s pain complaints and related limitations.
- The case was remanded to the Secretary for further proceedings consistent with the court’s opinion.

## Legal Principles

- Judicial review of a Social Security decision is limited to whether the decision is supported by substantial evidence and whether the correct legal standards were applied.
- Substantial evidence is more than a scintilla and less than a preponderance; it is relevant evidence a reasonable mind could accept as adequate to support the conclusion.
- An ALJ must consider subjective complaints of pain and limitation together with objective medical evidence; the ALJ may not reject such complaints without providing reasons grounded in the record.
- A finding that a claimant can perform past relevant work must rest on an RFC determination that accounts for all credible limitations supported by the record.

## Conclusion

The court remanded because the ALJ’s analysis did not adequately address Armstrong’s asserted pain and functional limits, and the resulting RFC and past-work finding were not supported by substantial evidence under the governing standards.


Armstrong v. Sullivan, 814 F. Supp. 1364 (W.D. Tex. 1993)