Earhart v. Commissioner, Social Security Administration

CourtDistrict Court, D. Colorado
DecidedApril 16, 2025
Docket1:24-cv-01784
StatusUnknown

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

Bluebook
Earhart v. Commissioner, Social Security Administration, (D. Colo. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLORADO

Civil Action No. 24-cv-01784-STV

B.E.,1

Plaintiff,

v.

LELAND DUDEK,2 Acting Commissioner of Social Security,

Defendant. ______________________________________________________________________

ORDER ______________________________________________________________________

Chief Magistrate Judge Scott T. Varholak

This matter is before the Court on Plaintiff B.E.’s Complaint seeking review of the Commissioner of Social Security’s decision denying Plaintiff’s application for disability insurance benefits (“DIB”) and supplemental security income (“SSI”) under Titles II and XVI of the Social Security Act (“SSA”), 42 U.S.C. §§ 401 et seq., and 1381-83c, respectively. [#1] The parties have both consented to proceed before this Court for all proceedings, including the entry of final judgment, pursuant to 28 U.S.C. § 636(c) and D.C.COLO.LCivR 72.2. [#16] The Court has jurisdiction to review the Commissioner’s

1 Pursuant to D.C.COLO.LAPR 5.2(b), “[a]n order resolving a social security appeal on the merits shall identify the plaintiff by initials only.” 2 Martin O’Malley is the named Defendant in the Complaint as he was the Commissioner of Social Security at the time the Complaint was filed. [#1] Leland Dudek currently serves as the Acting Commissioner of Social Security. https://www.ssa.gov/agency/commissioner (last accessed April 16, 2025). Pursuant to Federal Rule of Civil Procedure 25(d), Leland Dudek, as Commissioner O’Malley’s successor, “is automatically substituted as a party.” See also 42 U.S.C. § 405(g) (“Any action instituted in accordance with this subsection shall survive notwithstanding any change in the person occupying the office of Commissioner of Social Security or any vacancy in such office.”). final decision pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3). This Court has carefully considered the Complaint [#1], the Social Security Administrative Record [#10], the parties’ briefing [##11, 12, 13], and the applicable case law, and has determined that oral argument would not materially assist in the disposition of this appeal. For the

following reasons, the Court REVERSES the Commissioner’s decision and REMANDS this matter for further proceedings consistent with this Order. I. LEGAL STANDARD A. Five-Step Process for Determining Disability The Social Security Act defines disability as the 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.”3 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A); Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007). “This twelve-month duration requirement applies to the claimant’s inability to engage in any

substantial gainful activity, and not just his underlying impairment.” Lax, 489 F.3d at 1084. “In determining whether an individual’s physical or mental impairment or impairments are of a sufficient medical severity that such impairment or impairments could be the basis of eligibility . . ., the Commissioner [ ] shall consider the combined effect of all of the individual’s impairments without regard to whether any such impairment, if considered separately, would be of such severity.” 42 U.S.C. §§ 423(d)(2)(B), 1382c(a)(3)(G).

3 “Substantial gainful activity” is defined in the regulations as “work that (a) [i]nvolves doing significant and productive physical or mental duties; and (b) [i]s done (or intended) for pay or profit.” 20 C.F.R. §§ 404.1510, 416.910; see also 20 C.F.R. §§ 404.1572, 416.972. “The Commissioner is required to follow a five-step sequential evaluation process to determine whether a claimant is disabled.” Hackett v. Barnhart, 395 F.3d 1168, 1171 (10th Cir. 2005). The five-step inquiry is as follows: 1. The Commissioner first determines whether the claimant’s work activity, if any, constitutes substantial gainful activity; 2. If not, the Commissioner then considers the medical severity of the claimant’s mental and physical impairments to determine whether any impairment or combination of impairments is “severe;”4 3. If so, the Commissioner then must consider whether any of the severe impairment(s) meet or exceed a listed impairment in the appendix of the regulations; 4. If not, the Commissioner next must determine whether the claimant’s residual functional capacity (“RFC”)—i.e., the functional capacity the claimant retains despite his impairments—is sufficient to allow the claimant to perform his past relevant work, if any; 5. If not, the Commissioner finally must determine whether the claimant’s RFC, age, education and work experience are sufficient to permit the claimant to perform other work in the national economy. See 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4); Grogan v. Barnhart, 399 F.3d 1257, 1261 (10th Cir. 2005); Bailey v. Berryhill, 250 F. Supp. 3d 782, 784 (D. Colo. 2017). The claimant bears the burden of establishing a prima facie case of disability at steps one through four, after which the burden shifts to the Commissioner at step five to show that the claimant retains the ability to perform work in the national economy. Wells v. Colvin, 727 F.3d 1061, 1064 n.1 (10th Cir. 2013); Lax, 489 F.3d at 1084. “A finding that the claimant is disabled or not disabled at any point in the five-step review is conclusive and terminates the analysis.” Ryan v. Colvin, 214 F. Supp. 3d 1015, 1018 (D. Colo.

4 The regulations define severe impairment as “any impairment or combination of impairments which significantly limits [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. §§ 404.1520(c), 416.920(c). 2016) (citing Casias v. Sec’y of Health & Human Servs., 933 F.2d 799, 801 (10th Cir. 1991)). B. Standard of Review In reviewing the Commissioner’s decision, the Court’s review is limited to a

determination of “whether the Commissioner applied the correct legal standards and whether her factual findings are supported by substantial evidence.” Vallejo v.

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Related

Allen v. Barnhart
357 F.3d 1140 (Tenth Circuit, 2004)
Hackett v. Barnhart
395 F.3d 1168 (Tenth Circuit, 2005)
Grogan v. Barnhart
399 F.3d 1257 (Tenth Circuit, 2005)
Fischer-Ross v. Barnhart
431 F.3d 729 (Tenth Circuit, 2005)
Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Wall v. Astrue
561 F.3d 1048 (Tenth Circuit, 2009)
Wells v. Astrue
727 F.3d 1061 (Tenth Circuit, 2013)
Flaherty v. Astrue
515 F.3d 1067 (Tenth Circuit, 2008)
Vallejo v. Berryhill
849 F.3d 951 (Tenth Circuit, 2017)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Ryan v. Colvin
214 F. Supp. 3d 1015 (D. Colorado, 2016)
Bailey v. Berryhill
250 F. Supp. 3d 782 (D. Colorado, 2017)

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Earhart v. Commissioner, Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/earhart-v-commissioner-social-security-administration-cod-2025.