Allen v. O'Malley

CourtDistrict Court, S.D. Texas
DecidedAugust 8, 2025
Docket4:24-cv-02129
StatusUnknown

This text of Allen v. O'Malley (Allen v. O'Malley) 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
Allen v. O'Malley, (S.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT August 08, 2025 Nathan Ochsner, Clerk SOUTHERN DISTRICT OF TEXAS HOUSTON DIVISION

ETHAN ALLEN, § § Plaintiff, § § v. § CIVIL ACTION NO. 4:24-cv-2129 § FRANK BISIGNANO, § § Defendant. §

MEMORANDUM AND RECOMMENDATION

Plaintiff Ethan Allen (“Plaintiff”) filed this lawsuit against Defendant Frank Bisignano (the “Commissioner”) seeking review of the denial of benefits under Title XVI of the Social Security Act. (ECF Nos. 1, 7).1 Pending before the Court are the parties’ cross-motions for summary judgment. (ECF Nos. 7, 9).2 Based on a review of the motions, arguments, and relevant law, the Court RECOMMENDS the Commissioner’s Motion for Summary Judgment (ECF No. 9) be GRANTED IN PART AND DENIED IN PART and Plaintiff’s Motion for Summary Judgment (ECF No. 7) be GRANTED IN PART AND

1 Frank Bisignano was sworn in as the Commissioner of Social Security on May 15, 2025. Bisignano 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.”). 2 On October 21, 2024, this case was referred to the Undersigned for all purposes pursuant to 28 U.S.C. § 636(b)(1)(A) and (B) and Federal Rule of Civil Procedure 72. (ECF No. 10). DENIED IN PART. The Court FURTHER RECOMMENDS the case be REMANDED for further administrative proceedings, consistent with this

opinion. I. Background Plaintiff filed a claim for supplemental security income on October 7, 2020, alleging disability starting on October 2, 2020. (ECF No. 3-1 at 31).3

Plaintiff’s claims were initially denied by the Social Security Administration on July 29, 2021, and again on reconsideration on November 7, 2022. (Id.). On November 18, 2022, Plaintiff requested a hearing before an Administrative Law Judge. (Id.). On September 14, 2023, Administrative Law Judge Michelle

Whetsel (the “ALJ”) held a telephonic hearing. (Id.). Plaintiff was represented by counsel at the hearing. (Id.). Thomas J. Meunier, a vocational expert (“VE”), also appeared at the hearing. (Id.). On October 17, 2023, the ALJ issued a decision, finding Plaintiff not

disabled at Step Five.4 (Id. at 41). At Step One, the ALJ found Plaintiff had not engaged in substantial gainful activity since October 7, 2020, the

3 The Administrative Record in this case can be found at ECF No. 3. 4 In considering a disability claim, an ALJ must conduct a five-step evaluation that examines: (1) whether the claimant is currently engaged in substantial gainful activity; (2) whether the claimant has a severe impairment; (3) whether the claimant’s impairment meets or equals the severity of an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1; (4) whether the impairment prevents the claimant from doing past relevant work; and (5) whether the impairment prevents the claimant from doing any other work. Masterson v. Barnhart, 309 F.3d 267, 271 (5th Cir. 2002) (citing 20 C.F.R. § 404.1520). 2 application date. (Id. at 33). At Step Two, the ALJ found Plaintiff has the following severe impairments: “stroke with residual deficits, high blood

pressure, vision disorder, vertigo, anxiety/depression/bipolar disorder (20 CFR 416.920(c)).” (Id.). At Step Three, the ALJ found Plaintiff: “does not have an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments in 20 CFR Part 404, Subpart P,

Appendix 1 (20 CFR 416.920(d), 416.925 and 416.926).” (Id. at 34). The ALJ determined that Plaintiff has the Residual Functional Capacity (“RFC”) to: perform sedentary work as defined in 20 CFR 416.967(a) except the claimant can lift 20 pounds occasionally, 10 pounds frequently, stand and walk for about four hours and sit for about six hours in an eight-hour workday. The claimant can occasionally climb ramps and stairs, but should never climb ladders, ropes, or scaffolds. He can occasionally balance, stoop, kneel, crouch, and crawl. He should avoid concentrated exposure to extreme heat, extreme cold, fumes, dusts, odors, gases, poor ventilation, dangerous moving machinery, and wet, slippery, uneven surfaces. The claimant should avoid all exposure to unprotected heights. He can frequently reach in all directions, including overhead, bilaterally. The claimant can frequently handle and finger bilaterally. He can occasionally push, pull, and operate foot controls, bilaterally. The claimant can remember and follow simple instructions. He can perform the tasks assigned, but not at a production rate pace; however, he can meet the end of day work goals. The claimant can occasionally adapt to changes in the workplace.

(Id. at 35). At Step Four, the ALJ found Plaintiff “has no past relevant work.” (Id. at 40). At Step Five, the ALJ found there were jobs that existed in significant numbers in the national economy that Plaintiff could perform— 3 such as a parking lot cashier, food and beverage order clerk, and final assembler—and therefore Plaintiff was not disabled as defined under the

Social Security Act. (Id. at 40–41). Plaintiff appealed to the Appeals Council who denied Plaintiff’s request for review on March 15, 2024. (Id. at 6). Thus, the ALJ’s decision represents the Commissioner’s final decision in the case. See Sims v. Apfel, 530 U.S. 103,

106–07 (2000). II. Legal Standard The Court’s review of a final decision of the Commissioner on a Social Security disability claim is exceedingly deferential. Taylor v. Astrue, 706 F.3d

600, 602 (5th Cir. 2012). “[R]eview of Social Security disability cases ‘is limited to two inquiries: (1) whether the decision is supported by substantial evidence on the record as a whole, and (2) whether the Commissioner applied the proper legal standard.’” Copeland v. Colvin, 771 F.3d 920, 923 (5th Cir. 2014) (quoting

Perez v. Barnhart, 415 F.3d 457, 461 (5th Cir. 2005)). When the Commissioner’s decision is reached by applying improper legal standards, the decision is not supported by substantial evidence. Singletary v. Bowen, 798 F.2d 818, 823 (5th Cir. 1986). “Substantial evidence is ‘such relevant evidence

as a reasonable mind might accept to support a conclusion’ and constitutes ‘more than a mere scintilla’ but ‘less than a preponderance’ of evidence.” Hardman v. Colvin,

Related

Brown v. Apfel
192 F.3d 492 (Fifth Circuit, 1999)
Newton v. Apfel
209 F.3d 448 (Fifth Circuit, 2000)
Perez v. Barnhart
415 F.3d 457 (Fifth Circuit, 2005)
Audler v. Astrue
501 F.3d 446 (Fifth Circuit, 2007)
Joe Herrera v. Michael Astrue, Commissioner
406 F. App'x 899 (Fifth Circuit, 2010)
Uwe Taylor v. Michael Astrue, Commissioner
706 F.3d 600 (Fifth Circuit, 2012)
Sims v. Apfel
530 U.S. 103 (Supreme Court, 2000)
Patsy Copeland v. Carolyn Colvin, Acting Cmsnr
771 F.3d 920 (Fifth Circuit, 2014)
Charles Johnson, Jr. v. Carolyn Colvin, Acting Cms
595 F. App'x 443 (Fifth Circuit, 2015)
Johnnie Hardman v. Carolyn Colvin, Acting Cmsnr
820 F.3d 142 (Fifth Circuit, 2016)
Leah Heck v. Carolyn Colvin, Acting Cmsnr
674 F. App'x 411 (Fifth Circuit, 2017)

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Bluebook (online)
Allen v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/allen-v-omalley-txsd-2025.