Anderson v. Social Security Administration

CourtDistrict Court, D. New Mexico
DecidedJuly 25, 2022
Docket1:21-cv-00034
StatusUnknown

This text of Anderson v. Social Security Administration (Anderson v. Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, D. New Mexico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Anderson v. Social Security Administration, (D.N.M. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

LINDA M. ANDERSON,

Plaintiff,

vs. CIV No. 1:21-0034 KRS

KILOLO KIJAKAZI, Acting Commissioner of the Social Security Administration,

Defendant.

MEMORANDUM OPINION AND ORDER

THIS MATTER is before the Court upon Plaintiff Linda M. Anderson’s (“Plaintiff’s”) Opposed Motion to Reverse and/or Remand (Doc. 24), dated November 8, 2021, challenging the determination of the Commissioner of the Social Security Administration (“SSA”) that she is not entitled to disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. §§ 401-34. The Commissioner responded to Plaintiff’s Motion on March 2, 2022 (Doc. 32), and Plaintiff filed a reply brief on March 16, 2022 (Doc. 33). With the consent of the parties to conduct dispositive proceedings in this matter, see 28 U.S.C. § 636(c); FED. R. CIV. P. 73(b), the Court has considered the parties’ filings and has thoroughly reviewed the administrative record. Having done so, the Court concludes that the ALJ erred in his decision and will therefore GRANT Plaintiff’s Motion and remand this case back to the SSA for proceedings consistent with this opinion. I. PROCEDURAL POSTURE On September 11, 2014, Plaintiff filed an initial application for disability insurance benefits. (See Administrative Record (“AR”) at 175-76). Plaintiff alleged that she had become disabled on December 29, 2011. (Id. at 175). Her date last insured was December 31, 2015. (Id. at 1341). In 2016, Plaintiff’s application was denied at the initial level (id. at 73-83), and at the reconsideration level (id. at 85-97). ALJ Eric Weiss issued an unfavorable disability decision on February 28, 2018. (Id. at 16-28). Plaintiff appealed, and Magistrate Judge Gregory B. Wormuth of this District reversed and remanded Plaintiff’s case on February 4, 2020. (Id. at 1417-33). On remand, Plaintiff and a vocational expert (“VE”) testified at an administrative hearing conducted

telephonically by ALJ Weiss on October 14, 2020. (Id. at 1363-85). Plaintiff was represented by counsel, who also appeared by telephone. (Id. at 1363). Following that hearing, ALJ Weiss issued a second unfavorable disability decision on November 12, 2020. (Id. at 1335-59). On January 13, 2021, Plaintiff’s appeal of the November 2020 ALJ decision followed. (Doc. 1). It is ALJ Weiss’s second unfavorable disability decision that is at issue in this case. II. LEGAL STANDARDS A. Standard of Review Judicial review of the Commissioner’s decision is limited to determining “whether substantial evidence supports the factual findings and whether the ALJ applied the correct legal

standards.” Allman v. Colvin, 813 F.3d 1326, 1330 (10th Cir. 2016) (citing Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007)); see also 42 U.S.C. § 405(g). If substantial evidence supports the ALJ’s findings and the correct legal standards were applied, the Commissioner’s decision stands and the plaintiff is not entitled to relief. See, e.g., Langley v. Barnhart, 373 F.3d 1116, 1118 (10th Cir. 2004). Although a court must meticulously review the entire record, it “may neither reweigh the evidence nor substitute [its] judgment for that of the [Commissioner].” See, e.g., id. (quotation omitted). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” See Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (quotation omitted); Langley, 373 F.3d at 1118 (quotation omitted). Although this threshold is “not high,” evidence is not substantial if it is “a mere scintilla,” Biestek, 139 S. Ct. at 1154 (quotation omitted); “if it is overwhelmed by other evidence in the record[,]” Langley, 373 F.3d at 1118 (quotation omitted); or if it “constitutes mere conclusion[,]” Grogan v. Barnhart, 399 F.3d 1257, 1261-62 (10th Cir. 2005) (quotation omitted). Thus, the Court must examine the

record as a whole, “including anything that may undercut or detract from the ALJ’s findings in order to determine if the substantiality test has been met.” Grogan, 399 F.3d at 1262 (citation omitted). While an ALJ need not discuss every piece of evidence, “[t]he record must demonstrate that the ALJ considered all of the evidence,” Clifton v. Chater, 79 F.3d 1007, 1009-10 (10th Cir. 1996) (citation omitted), and “a minimal level of articulation of the ALJ’s assessment of the evidence is required in cases in which considerable evidence is presented to counter the agency’s position.” Id. at 1010 (quotation omitted). “Failure to apply the correct legal standard or to provide this court with a sufficient basis to determine that appropriate legal principles have been followed is grounds for reversal.” Byron v. Heckler, 742 F.2d 1232, 1235 (10th Cir. 1984)

(quotation and citation omitted). B. Disability Framework “Disability,” as defined by the Social Security Act, is the inability “to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than twelve months.” 42 U.S.C. § 423(d)(1)(A). The SSA has devised a five-step sequential evaluation process to determine disability. See Barnhart v. Thomas, 540 U.S. 20, 24 (2003); Wall v. Astrue, 561 F.3d 1048, 1051-52 (10th Cir. 2009); 20 C.F.R. § 404.1520. If a finding of disability or non-disability is directed at any point, the SSA will not proceed through the remaining steps. Thomas, 540 U.S. at 24. At the first three steps, the ALJ considers the claimant’s current work activity and the severity of her impairment or combination of impairments. See id. at 24-25. If no finding is directed after the third step, the Commissioner must determine the claimant’s residual functional capacity (“RFC”), or the most that she is able to do despite her limitations. See 20 C.F.R. §§ 404.1520(e), 404.1545(a)(1). At

step four, the claimant must prove that, based on her RFC, she is unable to perform the work she has done in the past. See Thomas, 540 U.S. at 25. If the claimant meets “the burden of establishing a prima facie case of disability[,] . . . the burden of proof shifts to the Commissioner at step five to show that” the claimant retains sufficient RFC “to perform work in the national economy, given [her] age, education and work experience.” Grogan, 399 F.3d at 1261 (citation omitted); see also Williams v. Bowen, 844 F.2d 748, 750-51 (10th Cir.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Barnhart v. Thomas
540 U.S. 20 (Supreme Court, 2003)
Gilbertson v. Allied Signal, Inc.
328 F.3d 625 (Tenth Circuit, 2003)
Langley v. Barnhart
373 F.3d 1116 (Tenth Circuit, 2004)
Grogan v. Barnhart
399 F.3d 1257 (Tenth Circuit, 2005)
Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Carpenter v. Astrue
537 F.3d 1264 (Tenth Circuit, 2008)
Wall v. Astrue
561 F.3d 1048 (Tenth Circuit, 2009)
Boardman v. Prudential Insurance Co. of America
337 F.3d 9 (First Circuit, 2003)
Martinez v. Astrue
422 F. App'x 719 (Tenth Circuit, 2011)
Wilson v. Colvin
541 F. App'x 869 (Tenth Circuit, 2013)
Tarpley v. Colvin
601 F. App'x 641 (Tenth Circuit, 2015)
Allman v. Colvin
813 F.3d 1326 (Tenth Circuit, 2016)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Anderson v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-social-security-administration-nmd-2022.