Chavez v. Social Security Administration

CourtDistrict Court, D. New Mexico
DecidedJanuary 4, 2021
Docket1:20-cv-00058
StatusUnknown

This text of Chavez v. Social Security Administration (Chavez 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
Chavez v. Social Security Administration, (D.N.M. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW MEXICO

DENNIS P. CHAVEZ,

Plaintiff,

v. No. 20-cv-0058 SMV

ANDREW SAUL, Commissioner of the Social Security Administration,

Defendant.

MEMORANDUM OPINION AND ORDER

THIS MATTER is before the Court on Plaintiff’s Motion to Reverse and Remand for a Rehearing with Supporting Memorandum [Doc. 17], filed on June 10, 2020. The Commissioner responded on August 18, 2020. [Doc. 18]. Plaintiff replied on August 25, 2020. [Doc. 19]. The parties have consented to my entering final judgment in this case. [Doc. 8]. Having meticulously reviewed the entire record and being fully advised in the premises, the Court finds a lack of substantial evidence to support some of the Administrative Law Judge’s factual findings. Those unsupported findings, therefore, cannot sustain the rejection of the opinions from Physician’s Assistant (“PA”) Maroney or Psychologist Baum. Accordingly, the Motion will be granted, and the case will be remanded for further proceedings. See 42 U.S.C. § 405(g) (sentence four) (2018). Standard of Review The standard of review in a Social Security appeal is whether the Commissioner’s final decision1 is supported by substantial evidence and whether the correct legal standards were

1 A court’s review is limited to the Commissioner’s final decision, 42 U.S.C. § 405(g), which generally is the ALJ’s decision, 20 C.F.R. §§ 404.981; 416.1481. This case fits the general framework, and therefore, the Court reviews the ALJ’s decision as the Commissioner’s final decision. applied. Maes v. Astrue, 522 F.3d 1093, 1096 (10th Cir. 2008). If substantial evidence supports the Commissioner’s findings and the correct legal standards were applied, the Commissioner’s decision stands and the plaintiff is not entitled to relief. Langley v. Barnhart, 373 F.3d 1116, 1118 (10th Cir. 2004). Courts must meticulously review the entire record, but may neither reweigh the evidence nor substitute their judgment for that of the Commissioner. Flaherty v. Astrue, 515 F.3d 1067, 1070 (10th Cir. 2007). “Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Langley, 373 F.3d at 1118. The decision “is not based on substantial evidence if it is overwhelmed by other evidence in the record or if there is a mere scintilla of evidence supporting it.” Id. While a court may not re-weigh the evidence or try the

issues de novo, its examination of the record as a whole must include “anything that may undercut or detract from the [Commissioner]’s findings in order to determine if the substantiality test has been met.” Grogan v. Barnhart, 399 F.3d 1257, 1262 (10th Cir. 2005). “The possibility of drawing two inconsistent conclusions from the evidence does not prevent [the] findings from being supported by substantial evidence.” Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007) (citing Zoltanski v. F.A.A., 372 F.3d 1195, 1200 (10th Cir. 2004)). “The 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.” Jensen v. Barnhart, 436 F.3d 1163, 1165 (10th Cir. 2005) (quotation marks omitted). Applicable Law and Sequential Evaluation Process

In order to qualify for disability benefits, a claimant must establish that he is unable “to engage in any substantial gainful activity by reason of any medically determinable physical or 2 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 12 months.” 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A) (2018); see 20 C.F.R. §§ 404.1505(a), 416.905(a) (2012). When considering a disability application, the Commissioner is required to use a five-step sequential evaluation process. Bowen v. Yuckert, 482 U.S. 137, 140 (1987); 20 C.F.R. §§ 404.1520, 416.920 (2012). At the first four steps of the evaluation process, the claimant must show: (1) he is not engaged in “substantial gainful activity”; and (2) he has a “severe medically determinable . . . impairment . . . or a combination of impairments” that has lasted or is expected to last for at least one year; and (3) his impairment(s) either meet or equal one of the “Listings”2 of presumptively disabling impairments; or (4) he is unable to perform his “past relevant work.”

§§ 404.1520(a)(4)(i)–(iv), 416.920(a)(4)(i)–(iv); see Grogan v. Barnhart, 399 F.3d 1257, 1261 (10th Cir. 2005). If he cannot show that his impairment meets or equals a Listing, but he proves that he is unable to perform his “past relevant work,” the burden of proof then shifts to the Commissioner, at step five, to show that the claimant is able to perform other work in the national economy, considering his residual functional capacity (“RFC”), age, education, and work experience. Grogan, 399 F.3d at 1261. Procedural Background Plaintiff applied for a period of disability, disability insurance benefits, and supplemental security income November 10, 2016. Tr. 15. He alleged a disability-onset date of September 24, 2016. Id. His claims were denied initially and on reconsideration. Id. Administrative Law Judge

2 20 C.F.R. pt. 404, subpt. P, app. 1. 3 (“ALJ”) Stephen Gontis held a hearing on September 9, 2018, in Albuquerque, New Mexico. Tr. 15, 34. Plaintiff appeared in person with his attorney. Tr. 15, 34. The ALJ heard testimony from Plaintiff and an impartial vocational expert (“VE”), Karen N. Provine. Tr. 15, 34–87. The ALJ issued his unfavorable decision on November 26, 2018. Tr. 15–28. He found that Plaintiff met the insured status requirements of the Social Security Act through December 31, 2017. Tr. 18. At step one, he found that Plaintiff had, in fact, engaged in substantial gainful activity (“SGA”) since September 24, 2016, his alleged onset date.3 Id. The ALJ found that Plaintiff performed SGA from November 2017 through the first quarter of 2018. Id. However, in the second and third quarters of 2018, Plaintiff’s part-time work was too little to amount to SGA. Id. Accordingly, the ALJ found that this work did not preclude Plaintiff’s disability claim, because

if Plaintiff were otherwise disabled, it would constitute an unsuccessful work attempt. Id. At step two, the ALJ found that Plaintiff suffered from the following severe impairments: degenerative joint disease of the bilateral knees and left shoulder, depression, and anxiety. Id.

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Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Watkins v. Barnhart
350 F.3d 1297 (Tenth Circuit, 2003)
Zoltanski v. Federal Aviation Administration
372 F.3d 1195 (Tenth Circuit, 2004)
Langley v. Barnhart
373 F.3d 1116 (Tenth Circuit, 2004)
Grogan v. Barnhart
399 F.3d 1257 (Tenth Circuit, 2005)
Haga v. Barnhart
482 F.3d 1205 (Tenth Circuit, 2007)
Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Frantz v. Astrue
509 F.3d 1299 (Tenth Circuit, 2007)
Maes v. Astrue
522 F.3d 1093 (Tenth Circuit, 2008)
Chapo v. Astrue
682 F.3d 1285 (Tenth Circuit, 2012)
Reveteriano v. Astrue
490 F. App'x 945 (Tenth Circuit, 2012)
Keyes-Zachary v. Astrue
695 F.3d 1156 (Tenth Circuit, 2012)
Wells v. Astrue
727 F.3d 1061 (Tenth Circuit, 2013)
Flaherty v. Astrue
515 F.3d 1067 (Tenth Circuit, 2008)

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Chavez v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chavez-v-social-security-administration-nmd-2021.