Cowan v. Social Security Administration

CourtDistrict Court, N.D. Oklahoma
DecidedJanuary 5, 2024
Docket4:22-cv-00421
StatusUnknown

This text of Cowan v. Social Security Administration (Cowan v. Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, N.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. Social Security Administration, (N.D. Okla. 2024).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OKLAHOMA

JOHN W. C., ) ) Plaintiff, ) ) v. ) Case No. 4:22-CV-421-CDL ) MARTIN O’MALLEY,1 ) Commissioner of the ) Social Security Administration, ) ) Defendant. )

OPINION AND ORDER Plaintiff seeks judicial review under 42 U.S.C. § 405(g) of a decision of the Commissioner of the Social Security Administration (Commissioner) denying disability benefits. The parties have consented to proceed before a United States Magistrate Judge in accordance with 28 U.S.C. § 636(c)(1), (2). For the reasons set forth below, the Court reverses the decision of the Commissioner and remands the case for further proceedings consistent with this Opinion and Order. I. Standard of Review The Social Security Act (Act) provides disability insurance benefits to qualifying individuals who have a physical or mental disability. See 42 U.S.C. § 423. The Act defines

1 On December 20, 2023, Martin O’Malley was sworn in as the Commissioner of the Social Security Administration. Pursuant to Federal Rule of Civil Procedure 25(d), O’Malley is substituted as the defendant in this action. No further action need be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g).

“disability” as an “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

12 months.” See id. § 423(d)(1)(A). Judicial review of a Commissioner’s disability determination “‘is limited to determining whether the Commissioner applied the correct legal standards and whether the agency’s factual findings are supported by substantial evidence.’” Noreja v. Soc. Sec. Comm’r, 952 F.3d 1172, 1177 (10th Cir. 2020) (citing Knight ex rel. P.K. v. Colvin, 756

F.3d 1171, 1175 (10th Cir. 2014)). “Substantial evidence is more than a mere scintilla and is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Id. at 1178 (quoting Grogan v. Barnhart, 399 F.3d 1257, 1261 (10th Cir. 2005)); see also Biestek v. Berryhill, --- U.S. ---, 139 S. Ct. 1148, 1154 (2019). “Evidence is not substantial if it is overwhelmed by other evidence in the record or constitutes mere

conclusion.” Noreja, 952 F.3d at 1178 (quoting Grogan, 399 F.3d at 1261-62). So long as supported by substantial evidence, the agency’s factual findings are “conclusive.” Biestek, 139 S. Ct. at 1152 (quoting 42 U.S.C. § 405(g)). The court may not reweigh the evidence or substitute its judgment for that of the agency. Noreja, 952 F.3d at 1178.

II. Background On May 6, 2020, the plaintiff filed an application for Title II disability insurance benefits. (R. 15). The plaintiff alleged that he became disabled on September 15, 2019, after having a stroke, due to a combination of impairments including diabetes, arthritis, stroke, right-knee injury, bipolar, depression, asthma, high blood pressure, and high cholesterol. (R. 59-60). He was 53 years old on the alleged onset date. (R. 59). The plaintiff has a post-high-school education. Before his alleged disability, he worked as a high-school

science teacher, and he worked in retail stores in the meat department and in maintenance. (R. 44-46). The Commissioner denied the plaintiff’s applications at the initial and reconsideration levels. State agency reviewing consultants determined that the plaintiff has severe impairments but that he retains the RFC to perform his past work as a teacher. (R.

59-84). The plaintiff then requested a hearing before an Administrative Law Judge (ALJ), who held a hearing by telephone on February 15, 2022. Testimony was given by the plaintiff and a vocational expert (VE). (See R. 34-57). The plaintiff testified that due to back pain and fatigue resulting from his stroke, he cannot stand or walk for very long. Due to diabetes, he also experiences neuropathy in his

legs and feet, and he has arthritis in his feet that makes it hard to walk some days. (R. 49- 51). The stroke resulted in reduced function on the left side of his body, so it takes him longer to get things done. He can lift about 5 or 10 pounds due to lower back pain. The plaintiff testified that he is unable to return to teaching because it was “mentally taxing” and “very stressful and . . . being under so much stress affects my depression.” (R. 46). He

stated that he attempted to work after his stroke in September 2019, but that he started having stroke-like symptoms that triggered a panic attack and seizures. (R. 49). The plaintiff stated that when he was teaching, he was standing or walking around the classroom for most of the day. He testified that now, his lower back becomes too painful if he is on his feet for more than 30 minutes. He uses acetaminophen and a heating pad to help with the pain, but he stopped taking opioids out of concern about addiction. He is able to vacuum and take care of other household chores, with breaks, and is independent with

self-care. (R. 50-51). The plaintiff further testified that his diabetes has affected his vision. He experiences “floaters” in his vision and has difficulty focusing at times, even with corrective lenses. (R. 48). On March 16, 2022, the ALJ issued a decision denying disability benefits. (R. 15- 34). On August 28, 2022, the Appeals Council denied the plaintiff’s request for review,

which rendered the ALJ’s decision the agency’s final decision. (R. 1-3). Following the Appeals Council’s denial, the plaintiff timely filed a Complaint in this Court. (See Doc. 2). Accordingly, the Court has jurisdiction to review the ALJ’s March 16, 2022 decision under 42 U.S.C. § 405(g). III. The ALJ’s Decision

The Commissioner uses a five-step, sequential process to determine whether a claimant is disabled. See 20 C.F.R. §§ 404.1520(a)(4)(i)-(v), 416.920(a)(4)(i)-(v). At step one, the ALJ determines whether the claimant is engaged in substantial gainful activity. At step two, the ALJ determines whether the claimant has an impairment or a combination of impairments that is severe. At step three, the ALJ determines whether the claimant’s severe

impairment or combination of impairments is equivalent to one that is listed in the applicable regulation, which the Commissioner “acknowledges are so severe as to preclude substantial gainful activity.” Williams v. Bowen, 844 F.2d 748, 751 (10th Cir. 1988) (internal quotation and citation omitted); see 20 C.F.R. § 404.1520(d); 20 C.F.R. Part 404, subpt. P, App’x 1 (Listings).

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Cowan v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cowan-v-social-security-administration-oknd-2024.