Cooper v. Kijakazi

CourtDistrict Court, District of Columbia
DecidedJuly 3, 2024
DocketCivil Action No. 2022-3828
StatusPublished

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

Bluebook
Cooper v. Kijakazi, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

WONZELL C., 1 Plaintiff, v. Civil Action No. 22-3828 (JDB) MARTIN O’MALLEY, Commissioner of Social Security, 2 Defendant.

MEMORANDUM OPINION & ORDER

Plaintiff Wonzell C. brought this action challenging the Commissioner of Social Security’s

final decision denying him supplemental security income benefits. See 42 U.S.C. § 405(g). Now

before the Court are Magistrate Judge Harvey’s Report and Recommendation (“R&R”), plaintiff’s

objection thereto, and the Commissioner’s response to that objection. For the reasons that follow,

the Court will reject plaintiff’s objection, adopt the R&R, and accordingly grant the

Commissioner’s motion for judgment of affirmance and deny plaintiff’s motion for judgment of

reversal.

Background

I. Statutory and Regulatory Framework

The Social Security Act of 1935 provides, as relevant here, for supplemental security

income benefits for financially eligible “disabled” individuals. 42 U.S.C. §§ 1381, 1382(a). “To

1 Based on a recommendation from the Committee on Court Administration and Case Management of the Judicial Conference of the United States, plaintiff’s name has been partially redacted due to privacy concerns. See Mem. from Hon. Wm. Terrell Hodges, Chair, Comm. on Ct. Admin. & Case Mgmt., to Chief Judges of the U.S. Cts. of Appeals et al. (May 1, 2018), https://www.uscourts.gov/sites/default/files/18-ap-c-suggestion_cacm_0.pdf [https://perma.cc/N9T2-U5XG]. 2 Pursuant to Federal Rule of Civil Procedure 25(d), the current Commissioner of Social Security is substituted as defendant.

1 be eligible for [supplemental security income] based on disability, a claimant must demonstrate

that disability prevents her from earning a living.” Cox v. Kijakazi, 77 F.4th 983, 986 (D.C. Cir.

2023). Specifically, the Act requires that a successful claimant be “unable to engage in any

substantial gainful activity by reason of any medically determinable physical or mental

impairment” that either “can be expected to result in death” or “has lasted or can be expected to

last for a continuous period of not less than twelve months.” 42 U.S.C. § 1382c(a)(3)(A). Any

such impairment must be severe enough that a claimant “is not only unable to do his previous work

but cannot, considering his age, education, and work experience, engage in any other kind of

substantial gainful work which exists in the national economy.” Id. § 1382c(a)(3)(B).

Claimants seeking supplemental security income benefits must apply to the Social Security

Administration, which evaluates claimants’ alleged conditions and determines whether each

claimant is indeed “disabled” within the meaning of the Act. Id. § 1383(c)(1)(A). If a claimant’s

initial application is denied, he may request a hearing before an administrative law judge (“ALJ”).

Id.; see also 20 C.F.R. § 416.1400. The ALJ then follows a “five-step sequential evaluation

process” to determine whether the claimant is disabled. 20 C.F.R. § 416.920; see also Cox, 77

F.4th at 986–87 (summarizing steps). As relevant here, the ALJ must ascertain the claimant’s

residual functional capacity, which is “the most [a claimant] can still do despite [his] limitations.”

20 C.F.R. § 416.945(a)(1); see also Cox, 77 F.4th at 986 (noting that the “residual functional

capacity inquiry is designed to determine the claimant’s uppermost ability to perform regular and

continuous work-related physical and mental activities in a work environment” (internal quotation

marks omitted)). In determining a claimant’s residual functional capacity, the ALJ conducts a

holistic analysis, considering each of the claimant’s “medically determinable impairments” and

“all the relevant evidence in [the] case record.” 20 C.F.R. § 416.945(a)(1)–(2).

2 When considering mental impairments (as opposed to physical ones), the ALJ evaluates

the severity of the claimant’s impairments across four broad functional areas: the abilities to (1)

“[u]nderstand, remember, or apply information,” (2) “interact with others,” (3) “concentrate,

persist, or maintain pace,” and (4) “adapt or manage oneself.” Id. § 416.920a(c)(3). The claimant’s

impairment in each area is assessed on a five-step scale: “[n]one, mild, moderate, marked, [or]

extreme.” Id. § 416.920a(c)(4).

The ALJ ultimately uses the residual functional capacity to determine whether the claimant

can still work—either with reference to the claimant’s past relevant work or with reference to other

jobs in the national economy to which the claimant could adjust. 42 U.S.C. § 1382c(a)(3)(B). If

so, the claimant is not disabled within the meaning of the Act. Id.

II. Factual Background and Procedural History

The Court adopts Judge Harvey’s thorough description of plaintiff’s claims, the procedural

history, and the ALJ’s decision, see R&R [ECF No. 17] at 4–15, and will only briefly highlight

the points that bear on plaintiff’s objection to the R&R.

Plaintiff applied for a period of disability and disability insurance benefits under Title II of

the Social Security Act in July 2019, and for supplemental security income benefits under Title

XVI of the Act in September 2019. Admin. R. [ECF No. 8] (“AR”) at 371, 373. His case

proceeded through the administrative review process. In January 2021, plaintiff amended his

alleged disability onset date and withdrew his Title II claim, leaving only his claim for

supplemental security income benefits. Id. at 1189–90; see id. at 16. An ALJ held a hearing in

February 2022 and subsequently issued a decision concluding that plaintiff was not “disabled”

within the meaning of the Act and thus not entitled to benefits. Id. at 15, 34.

3 As relevant here, the ALJ considered opinion evidence submitted by seven medical

professionals, including Dr. Maia Coleman King, a licensed psychologist, and Dr. Lalit Narayan,

plaintiff’s primary care provider. See id. at 30–31. The ALJ found many of these professionals’

opinions persuasive, but found Dr. King’s and Dr. Narayan’s opinions unpersuasive due largely to

a lack of consistency with the rest of the evidence. Id. at 31; see 20 C.F.R. § 404.1520c(a), (c)(1)–

(2) (providing that ALJs shall not “defer or give any specific evidentiary weight . . . to any medical

opinion(s)” but rather shall “evaluate the[ir] persuasiveness” in light of, inter alia, their support in

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Cooper v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cooper-v-kijakazi-dcd-2024.