Dina Halsey-Ricks v. P Social Security Administration, Commissioner

2024 DNH 060
CourtDistrict Court, D. New Hampshire
DecidedJuly 23, 2024
Docket23-cv-481-LM
StatusPublished
Cited by1 cases

This text of 2024 DNH 060 (Dina Halsey-Ricks v. P Social Security Administration, Commissioner) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

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Dina Halsey-Ricks v. P Social Security Administration, Commissioner, 2024 DNH 060 (D.N.H. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

Dina Halsey-Ricks

v. Civil No. 23-cv-481-LM Opinion No. 2024 DNH 060 P Social Security Administration, Commissioner

ORDER

Plaintiff Dina Halsey-Ricks brought this action seeking judicial review of the

decision of the Commissioner of the Social Security Administration (“the

Commissioner”) denying her applications for disability insurance benefits under

Title II of the Social Security Act. Halsey-Ricks moves to reverse the

Commissioner’s decision (doc. no. 26), and the Commissioner moves to affirm (doc.

no. 27). Ricks argues that an Administrative Law Judge (“ALJ”) erred by failing to

account for her treating physicians’ medical opinions in assessing her residual

functional capacity; by failing to assess her ability to work sustainably; by failing to

address all factors under 20 C.F.R. § 404.1520c(c); and by failing to consider Halsey-

Ricks’s medical conditions in evaluating jobs recommended by a vocational expert.

For the following reasons, the court affirms the Commissioner’s decision.

STANDARD OF REVIEW

In reviewing the final decision of the Commissioner under 42 U.S.C. § 405(g),

the court “is limited to determining whether the ALJ deployed the proper legal

standards and found facts upon the proper quantum of evidence.” Nguyen v. Chater, 172 F.3d 31, 35 (1st Cir. 1999); accord Sacilowski v. Saul, 959 F.3d 431, 437 (1st Cir.

2020). The court defers to the ALJ's factual findings if they are supported by

substantial evidence. 42 U.S.C. § 405(g); see also Fischer v. Colvin, 831 F.3d 31, 34

(1st Cir. 2016). “Substantial-evidence review is more deferential than it might

sound to the lay ear: though certainly ‘more than a scintilla’ of evidence is required

to meet the benchmark, a preponderance of evidence is not.” Purdy v. Berryhill, 887

F.3d 7, 13 (1st Cir. 2018) (citation omitted). Rather, the court “must uphold the

Commissioner's findings if a reasonable mind, reviewing the evidence in the record

as a whole, could accept it as adequate to support her conclusion.” Id. (citation and

alterations omitted).

DISABILITY ANALYSIS FRAMEWORK

The Social Security Administration’s regulations set out a five-step,

sequential process that ALJs must follow to evaluate whether a person is “disabled”

under the Social Security Act—that is, unable to engage in any “substantial gainful

activity.” See 42 U.S.C. § 423(d)(1)(A); 20 C.F.R. § 404.1520. The five steps are as

follows:

• Step One: If the claimant is presently engaging in substantial gainful activity, she is not disabled. § 404.1520(b). If the claimant is not engaging in substantial gainful activity, the ALJ proceeds to the second step. Id. § 404.1520(a)(4).

• Step Two: If the claimant does not have any impairment or any combination of impairments that significantly limits her physical or mental ability to do basic work activities, she is not disabled because she lacks a “severe” impairment. Id. § 404.1520(c). If the

2 claimant has a severe impairment or combination of impairments, the ALJ proceeds to the third step. Id. § 404.1520(a)(4).

• Step Three: If any of the claimant’s impairments meet or equal one of the impairments listed in 20 C.F.R. Part 404, Subpart P, Appendix 1, she is disabled—and the ALJ need not proceed to steps four and five. Id. § 404.1520(d). If the claimant’s impairments do not meet or equal the listed impairments, the ALJ proceeds to the fourth step. Id. § 404.1520(a)(4).

• Step Four: If the claimant’s impairments do not prevent her from doing her past relevant work, then she is not disabled. Id. § 404.1520(e)-(f). If the claimant is unable to do her past relevant work, the ALJ proceeds to the fifth step. Id. § 404.1520(a)(4).

• Step Five: If the claimant’s impairments do not prevent her from doing other work that exists in the national economy, then she is not disabled. Id. § 404.1520(g). If the claimant is not able to do other work, then she is disabled. Id. § 404.1520(a)(4).

At steps one through four, the claimant has the burden of proof. Sacilowski,

959 F.3d at 433-34. At step five, however, the Commissioner has the burden of

proof. Id.

If the claimant meets her burden at the first two steps of the sequential

analysis, but not at the third, the ALJ proceeds to steps four and five, which begin

with a determination of the claimant’s “residual functional capacity,” i.e., a

determination of what kinds of things the claimant can and cannot do, mentally and

physically. See 20 C.F.R. § 404.1545(a)(1). A person’s residual functional capacity is

an assessment of “the most” the claimant can do despite her limitations. Id. After

the ALJ determines the claimant’s residual functional capacity, the ALJ compares

that assessment against the demands of the claimant’s past work (at step four) and

3 against other jobs that exist in the national economy (at step five). § 404.1520(e)-(g).

If the claimant’s residual functional capacity allows her to perform her past

relevant work or work that exists in the national economy, the claimant is not

disabled. See § 404.1520(a)(4)(iv)-(v), (e), (f).

BACKGROUND1

Halsey-Ricks applied for disability insurance benefits in September 2019. She

claimed a disability beginning on November 1, 2018, and was last insured on

December 31, 2020. Halsey-Ricks alleged impairments including “multiple chemical

sensitivity” and myriad symptoms related to her sensitivity. The Social Security

Administration denied Halsey-Ricks’s application, and she timely requested

reconsideration. The Social Security Administration upheld the denial, and Halsey-

Ricks requested a hearing before an ALJ. The ALJ held a hearing in May 2021.2

During the hearing, Halsey-Ricks and a vocational expert testified. Halsey-

Ricks was 52 years old at the time of the hearing. She has a master’s degree in

psychology and started but did not finish a Ph.D. in child clinical psychology.

Halsey-Ricks was the director of clinical services at a child crisis center for 13 years,

until her multiple chemical sensitivity forced her to stop working in 2015. Halsey-

Ricks testified that her multiple chemical sensitivity rendered her allergic to “pretty

much everything.” Administrative Record (“AR”) at 44. Among her allergy triggers,

1 The court recounts only the facts of Halsey-Ricks’s extensive medical record

that are needed to resolve the issues she raised.

2 The ALJ held the hearing by telephone with the assent of all parties because

of the extraordinary circumstances presented by the COVID-19 pandemic.

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