Alford v. Kijakazi

CourtDistrict Court, S.D. Texas
DecidedSeptember 19, 2024
Docket3:23-cv-00152
StatusUnknown

This text of Alford v. Kijakazi (Alford v. Kijakazi) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Alford v. Kijakazi, (S.D. Tex. 2024).

Opinion

UNITED STATES DISTRICT COURT September 19, 2024 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk GALVESTON DIVISION PAMELA H. ALFORD, § § Plaintiff. § § V. § CIVIL ACTION NO. 3:23-cv-00152 § COMMISSIONER OF SOCIAL § SECURITY, § § Defendant. §

OPINION AND ORDER Plaintiff Pamela Alford (“Alford”) seeks judicial review of an administrative decision denying her application for disability insurance benefits under Title II of the Social Security Act (the “Act”). See Dkt. 1 Alford and Defendant Martin O’Malley, the Commissioner of the Social Security Administration (the “Commissioner”),1 have both filed briefs. See Dkts. 13, 14. After reviewing the briefing, the record, and the applicable law, I affirm the Commissioner’s decision. BACKGROUND On September 22, 2020, Alford filed an application for Title II disability insurance benefits alleging disability beginning on May 1, 2020. Her application was denied and denied again upon reconsideration. Subsequently, an Administrative Law Judge (“ALJ”) held a hearing and found that Alford was not disabled. Alford filed an appeal with the Appeals Council. The Appeals Council denied review, making the ALJ’s decision final and ripe for judicial review.

1 Martin O’Malley became the Commissioner of Social Security on December 20, 2023. O’Malley is “automatically substituted” as the defendant in this suit. FED. R. CIV. P. 25(d); see also 42 U.S.C. § 405(g) (“Any action instituted in accordance with this subsection shall survive notwithstanding any change in the person occupying the office of Commissioner of Social Security or any vacancy in such office.”). APPLICABLE LAW The standard of judicial review for disability appeals is provided in 42 U.S.C. § 405(g). See Waters v. Barnhart, 276 F.3d 716, 718 (5th Cir. 2002). Courts reviewing the Commissioner’s denial of social security disability applications limit their analysis to (1) “whether the Commissioner applied the proper legal standards,” and (2) whether the Commissioner’s factual findings are supported by substantial evidence. Estate of Morris v. Shalala, 207 F.3d 744, 745 (5th Cir. 2000). Addressing the evidentiary standard, the Fifth Circuit has explained: Substantial evidence is that which is relevant and sufficient for a reasonable mind to accept as adequate to support a conclusion; it must be more than a scintilla, but it need not be a preponderance. It is the role of the Commissioner, and not the courts, to resolve conflicts in the evidence. As a result, [a] court cannot reweigh the evidence, but may only scrutinize the record to determine whether it contains substantial evidence to support the Commissioner’s decision. A finding of no substantial evidence is warranted only where there is a conspicuous absence of credible choices or no contrary medical evidence. Ramirez v. Colvin, 606 F. App’x 775, 777 (5th Cir. 2015) (cleaned up). Judicial review is limited to the reasons relied on as stated in the ALJ’s decision, and post hoc rationalizations are not to be considered. See SEC v. Chenery Corp., 332 U.S. 194, 196 (1947). Under the Act, “a claimant is disabled only if she is incapable of engaging in any substantial gainful activity.” Anthony v. Sullivan, 954 F.2d 289, 293 (5th Cir. 1992) (cleaned up). The ALJ uses a five-step approach to determine if a claimant is disabled, including: (1) whether the claimant is presently performing substantial gainful activity; (2) whether the claimant has a severe impairment; (3) whether the impairment meets or equals a listed impairment; (4) whether the impairment prevents the claimant from doing past relevant work; and (5) whether the impairment prevents the claimant from performing any other substantial gainful activity. Salmond v. Berryhill, 892 F.3d 812, 817 (5th Cir. 2018) (quoting Kneeland v. Berryhill, 850 F.3d 749, 753 (5th Cir. 2017)). The burden of proof lies with the claimant during the first four steps before shifting to the Commissioner at Step 5. See Salmond, 892 F.3d at 817. Between Steps 3 and 4, the ALJ considers the claimant’s residual functional capacity (“RFC”), which serves as an indicator of the claimant’s capabilities given the physical and mental limitations detailed in the administrative record. See Kneeland, 850 F.3d at 754. The RFC also helps the ALJ “determine whether the claimant is able to do her past work or other available work.” Id. THE ALJ’S DECISION The ALJ found at Step 1 that Alford “has not engaged in substantial gainful activity since May 1, 2020, the alleged onset date.” Dkt. 9-3 at 21. The ALJ found at Step 2 that Alford suffers from “the following severe impairments: diabetes mellitus, psoriatic arthritis, cirrhosis, hepatic encephalopathy, gastroparesis syndrome, morbid obesity, disorders of the lumbar spine, and obstructive sleep apnea.” Id. The ALJ found that Alford’s “medically determinable mental impairments of anxiety and depression, considered singly and in combination, do not cause more than minimal limitation in [Alford]’s ability to perform basic mental work activities and are therefore non-severe.” Id. at 22. At Step 3, the ALJ found that none of these impairments meets or medically equals any of the Social Security Administration’s listed impairments. Prior to consideration of Step 4, the ALJ determined Alford’s RFC as follows: [Alford] has the residual functional capacity to perform work at the light exertional level with the following non-exertional limitations: [Alford] can occasionally climb ramps and stairs, but can never climb ladders, ropes or scaffolds; occasionally balance, stoop, kneel and crouch, but can never crawl; can never work at unprotected heights or around moving mechanical parts; can never operate heavy equipment or drive a motor vehicle for commercial purposes; and must avoid all exposure to open flames and open bodies of water. Id. at 26. At Step 4, the ALJ found that Alford “is capable of performing past relevant work as a budget accountant” because “[t]his work does not require the performance of work-related activities precluded by [Alford]’s residual functional capacity.” Id. at 28. Accordingly, the ALJ determined that Alford is not disabled. DISCUSSION This social security appeal raises one issue: whether the ALJ erred by failing to account for the total limiting effects of Alford’s severe and non-severe impairments. I answer that question in the negative. A. ANY ERROR BY THE ALJ AT STEP 2 WAS HARMLESS Alford first takes issue with “the ALJ’s patently unreasonable finding that her anxiety and depression were non[-]severe impairments.” Dkt. 13 at 17. This argument is without merit because the ALJ proceeded past Step 2, so any error was harmless. See Jones v. Astrue, 821 F. Supp. 2d 842, 850 (N.D. Tex. 2011) (failure to find an impairment severe at Step 2 “is not reversible [error] if the ALJ proceeded beyond the second step of the five-step sequential analysis in analyzing the claimant’s impairments, thereby allowing the district court to infer that the ALJ did find the impairment severe”).

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Related

Estate of Morris v. Shalala
207 F.3d 744 (Fifth Circuit, 2000)
Carey v. Apfel
230 F.3d 131 (Fifth Circuit, 2000)
Waters v. Barnhart
276 F.3d 716 (Fifth Circuit, 2002)
Securities & Exchange Commission v. Chenery Corp.
332 U.S. 194 (Supreme Court, 1947)
Jones v. Astrue
821 F. Supp. 2d 842 (N.D. Texas, 2011)
Linda Ramirez v. Carolyn Colvin, Acting Cmsnr
606 F. App'x 775 (Fifth Circuit, 2015)
Olivia Kneeland v. Nancy Berryhill, Acting Cmsnr
850 F.3d 749 (Fifth Circuit, 2017)
Rogelio Garcia v. Nancy Berryhill, Acting Cmsnr
880 F.3d 700 (Fifth Circuit, 2018)
Ronald Salmond, Sr. v. Nancy Berryhill, Acting Cms
892 F.3d 812 (Fifth Circuit, 2018)

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Bluebook (online)
Alford v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/alford-v-kijakazi-txsd-2024.