Courts v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedJanuary 15, 2025
Docket6:24-cv-00016
StatusUnknown

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

Bluebook
Courts v. Social Security Administration, (E.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

DIANA COURTS, ) ) Plaintiff, ) ) v. ) Case No. CIV-24-016-SPS ) CAROLYN COLVIN, ) Commissioner of the Social ) Security Administration, ) ) Defendant. )

OPINION AND ORDER The claimant Diana Courts requests judicial review pursuant to 42 U.S.C. § 405(g) of the denial of benefits by the Commissioner of the Social Security Administration. She appeals the Commissioner’s decision and asserts that the Administrative Law Judge (“ALJ”) erred in determining that she was not disabled. For the reasons discussed below, the Commissioner’s decision is hereby REVERSED and REMANDED to the ALJ for further proceedings. Social Security Law and Standard of Review Disability under the Social Security Act is defined as the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment[.]” 42 U.S.C. § 423(d)(1)(A). A claimant is disabled under the Social Security Act “only if his physical or mental impairment or impairments are of such severity that he 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. § 423 (d)(2)(A). Social security regulations implement a five-step sequential process to evaluate a disability claim. See 20 C.F.R. §§ 404.1520, 416.920.1 Section 405(g) limits the scope of judicial review of the Commissioner’s decision to two inquiries: whether the decision was supported by substantial evidence and whether correct legal

standards were applied. See Hawkins v. Chater, 113 F.3d 1162, 1164 (10th Cir. 1997). Substantial evidence is “‘more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Richardson v. Perales, 402 U.S. 389, 401 (1971) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). See also Clifton v. Chater, 79 F.3d 1007, 1009 (10th Cir. 1996). The Court may not reweigh the evidence or substitute its discretion for the Commissioner’s. See Casias v. Secretary of Health & Human Services, 933 F.2d 799, 800 (10th Cir. 1991). But the Court must review the record as a whole, and “[t]he substantiality of evidence must take into account whatever in the record fairly detracts from its weight.” Universal Camera Corp. v. NLRB, 340 U.S. 474, 488 (1951). See also Casias, 933 F.2d at 800-01.

Claimant’s Background

1 Step one requires the claimant to establish that she is not engaged in substantial gainful activity. Step two requires the claimant to establish that she has a medically severe impairment (or combination of impairments) that significantly limits her ability to do basic work activities. If the claimant is engaged in substantial gainful activity, or her impairment is not medically severe, disability benefits are denied. If she does have a medically severe impairment, it is measured at step three against the listed impairments in 20 C.F.R. Part 404, Subpt. P, App. 1. If the claimant has a listed (or “medically equivalent”) impairment, she is regarded as disabled and awarded benefits without further inquiry. Otherwise, the evaluation proceeds to step four, where the claimant must show that she lacks the residual functional capacity (“RFC”) to return to her past relevant work. At step five, the burden shifts to the Commissioner to show there is significant work in the national economy that the claimant can perform, given her age, education, work experience, and RFC. Disability benefits are denied if the claimant can return to any of her past relevant work or if her RFC does not preclude alternative work. See generally Williams v. Bowen, 844 F.2d 748, 750-51 (10th Cir. 1988). Claimant was born on December 4, 1958, and was 62 years old on the alleged disability onset date. (Tr. 174). She was 64 years old at the time of the administrative hearing. (Tr. 32). She has completed her high school education and has past relevant work experience as an outpatient receptionist. (Tr. 38-39, 55, 198). Claimant alleges she has been unable to work since November

19, 2021. (Tr. 17, 174). Procedural History Claimant filed applications for Title II disability insurance benefits, and supplemental security income benefits under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381-85. (Tr. 15). Her applications were denied. ALJ Doug Gabbard, II held an administrative hearing on April 19, 2023 (Tr. 32-59), and determined that Claimant was not disabled in a written decision dated May 26, 2023. (Tr. 12-31). The Appeals Council denied review, and the ALJ’s written opinion became the final decision of the Commissioner for purposes of appeal. Decision of the Administrative Law Judge In the May 26, 2023, decision, the ALJ made his decision at step four of the sequential

evaluation. At step two, the ALJ found that Claimant had several severe physical impairments, including rheumatoid arthritis, status post right knee arthroscopic surgery, and right foot hallux valgus deformity (20 CFR 404.1520(c)). (Tr. 17). The ALJ considered Claimant’s non-severe impairments including chronic lymphatic leukemia, leukocytosis, migraines/headaches, status post hysterectomy, GERD, dermatophytosis of nail, carpal tunnel syndrome (CTS), irritable bowel syndrome (IBS), hypothyroidism, bilateral cataract surgery, radial keratotomies, nicotine dependence, and osteoarthritis. (Tr. 17-18). Finally, the ALJ considered Claimant’s “medically determinable mental impairment of depressive/bipolar disorder” and found it did not cause “more than minimal limitation in her ability to perform basic mental work activities and [was] therefore nonsevere.” (Tr. 18). Next, the ALJ found that Claimant’s impairments did not meet a listing. (Tr. 19). At step four, the ALJ found that Claimant retained the residual functional capacity (“RFC”) to perform

light work as defined in 20 C.F.R. § 404.1567(b) with the following qualifications: occasional climbing, balancing, stooping, kneeling, crouching, and crawling; and frequent bilateral handling and fingering. (Tr. 20). Lastly, the ALJ proceeded to step four and determined that Claimant was not disabled because she could return to her past relevant work. (Tr. 25). Review During the relevant period the medical evidence primarily pertains to Claimant’s treatment for rheumatoid arthritis (“RA”). Rheumatologist Dr.

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