Cowan v. Commissioner of Social Security Administration

CourtDistrict Court, W.D. Oklahoma
DecidedOctober 6, 2025
Docket5:24-cv-01203
StatusUnknown

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

Bluebook
Cowan v. Commissioner of Social Security Administration, (W.D. Okla. 2025).

Opinion

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

M.W.C.,1 ) ) Plaintiff, ) ) v. ) Case No. CIV-24-1203-STE ) FRANK BISIGNANO, ) Commissioner of Social ) Security, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER Plaintiff brings this action pursuant to 42 U.S.C. § 405(g) for judicial review of the final decision of the Commissioner of the Social Security Administration denying Plaintiff's application for benefits under the Social Security Act (the Act). The Commissioner has answered and filed a transcript of the administrative record (hereinafter TR. ____). The parties have consented to disposition by a magistrate judge under 28 U.S.C. § 636(c). The parties have briefed their positions, and the matter is now at issue. The Commissioner's decision is REVERSED and REMANDED. I. PROCEDURAL BACKGROUND Plaintiff applied for disability insurance benefits under Title II of the Act alleging disability beginning February 1, 2021. The Social Security Administration denied Plaintiff's

1 The Court uses only Plaintiff’s initials to protect his privacy. application for benefits. Following an administrative hearing, (TR. 31-42),2 an Administrative Law Judge (ALJ) issued an unfavorable decision. (TR. 18-25). The Appeals Council denied Plaintiff's request for review, (TR. 1-5), making the decision of the ALJ the

final decision of the Commissioner. II. THE ADMINISTRATIVE DECISION The ALJ followed the five-step sequential evaluation process required by agency regulations. , 431 F.3d 729, 731 (10th Cir. 2005); 20 C.F.R. § 404.1520. At step one, the ALJ determined that Plaintiff did not engage in substantial gainful activity after her alleged onset date. (TR. 20).

At step two, the ALJ determined Plaintiff suffers from the severe impairment of “hypertension with dizziness/vertigo.” (TR. 21). At step three, the ALJ found that Plaintiff's impairments, considered individually or in combination, did not meet or medically equal any of the presumptively disabling impairments listed at 20 C.F.R. Part 404, Subpart P, Appendix 1. (TR. 21). At step four, the ALJ concluded Plaintiff has the residual functional capacity (RFC)3 to

perform “light work” as defined in 20 C.F.R. 404.1567(b), except that the claimant can only: never climb ladders, ropes, or scaffolds; never kneel, crouch, or crawl; occasionally balance and stoop; occasionally climb ramps

2 Citations to court filings are to the CM/ECF pagination. Citations to the administrative record (TR. ____) are to its original pagination.

3 Residual functional capacity “is the most [a claimant] can still do despite [a claimant’s] limitations.” 20 C.F.R. § 404.1545(a)(1). and stairs; and must avoid exposure to workplace hazards, such as dangerous moving machinery and unprotected heights.

(TR. 21). The ALJ next found Plaintiff could perform his past relevant work as a realtor (DOT #250.357-018) and a business owner (DOT #185.167-046). (TR. 24). The ALJ therefore concluded Plaintiff was not disabled. (TR. 24). III. ISSUES PRESENTED On appeal, Plaintiff argues: (1) the ALJ’s hypothetical question to the vocational expert was “fatally flawed” and his assessment of Plaintiff’s RFC is not supported by substantial evidence (ECF No. 12:3-7); (2) the ALJ failed to properly develop the record (ECF No. 12:7-9); (3) the ALJ failed to properly consider Plaintiff’s past work at Step Four of the sequential evaluation process (ECF No. 12:10-13); and (4) the ALJ’s evaluation of Plaintiff’s subjective complaints under Social Security Ruling 16-3p fails to salvage the ALJ’s errors. (ECF No. 12:13-15).

IV. STANDARD OF REVIEW This Court reviews the Commissioner's final decision “to determin[e] whether the Commissioner applied the correct legal standards and whether the agency’s factual findings are supported by substantial evidence.” , 952 F.3d. 1172, 1177 (10th Cir. 2020) (citation modified). Under the “substantial evidence” standard, a court looks to an existing

administrative record and asks whether it contains “sufficient evidence to support the agency’s factual determinations.” , 587 U.S. 97, 102 (2019) (citation modified). “Substantial evidence . . . is more than a mere scintilla. It means—and means only—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” at 103 (citation modified). While the court considers whether the ALJ followed the applicable rules of law in weighing evidence in disability cases, the court will

“neither reweigh the evidence nor substitute [its] judgment for that of the agency.” , 805 F.3d 1199, 1201 (10th Cir. 2015) (citation modified). Nevertheless, the Court must reverse decisions if the ALJ has simply picked out and relied on evidence that supports his conclusion without discussing relevant evidence to the contrary. V. PLAINTIFF’S RFC AND QUESTION TO THE VOCATIONAL EXPERT ARE NOT SUPPORTED BY SUBSTANTIAL EVIDENCE

Plaintiff claims his RFC assessment is unsupported by substantial evidence and the related hypothetical question to the vocational expert was “fatally flawed” because the ALJ failed in both instances to account for Plaintiff’s back pain. (ECF No. 12:3-7). The ALJ assessed Plaintiff with the RFC to perform “light work” as defined in 20 C.F.R. 404.1567(b), except that the claimant can only: never climb ladders, ropes, or scaffolds; never kneel, crouch, or crawl; occasionally balance and stoop; occasionally climb ramps and stairs; and must avoid exposure to workplace hazards, such as dangerous moving machinery and unprotected heights.

(TR. 21). At the administrative hearing, the ALJ asked the vocational expert a related hypothetical question about what kinds of jobs a worker with a similar RFC could perform, and the expert testified that such a worker could perform Plaintiff’s past relevant work. (TR. 40-41). Plaintiff seems to argue that because his RFC assessment is unsupported by substantial evidence, the vocational expert’s testimony based on the related hypothetical question cannot support the Commissioner’s decision. , 945 F.2d 1482, 1492 (10th Cir. 1991) (“Testimony elicited by hypothetical questions that do not relate with precision all of a claimant’s impairments cannot constitute substantial evidence to support the [Commissioner’s] decision.” (citation modified)). The

undersigned agrees Plaintiff’s RFC assessment is unsupported by substantial evidence because it does not account for Plaintiff’s back pain; the ALJ’s related hypothetical question was similarly flawed. (ECF No. 12:4-7). Under Social Security Ruling 96-8p, the ALJ ”must consider limitations and restrictions imposed by all of an individual’s impairments, even those that are not ‘severe.’” SSR 96-8p, 1996 WL 374184, *5 (July 2, 1996); 20 C.F.R.

§§ 404.1520(a)(3), 404.1545(a)(2).

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Cowan v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cowan-v-commissioner-of-social-security-administration-okwd-2025.