Fletcher v. Kijakazi Case remanded for further administrative proceedings.

CourtDistrict Court, S.D. Texas
DecidedFebruary 13, 2025
Docket4:23-cv-04150
StatusUnknown

This text of Fletcher v. Kijakazi Case remanded for further administrative proceedings. (Fletcher v. Kijakazi Case remanded for further administrative proceedings.) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fletcher v. Kijakazi Case remanded for further administrative proceedings., (S.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT February 13, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION

Cesar F., § § Plaintiff, § § Civil Action No. 4:23-cv-04150 v. § § Martin O’Malley,1 § Commissioner of the Social § Security Administration, § § Defendant. §

MEMORANDUM AND RECOMMENDATION This appeal from an administrative ruling denying social security benefits was referred to the undersigned judge. Dkt. 9. After carefully considering the parties’ cross-motions for summary judgment and briefs in support, Dkt. 10, 12, 13, the record, Dkt. 8, and the applicable law, it is recommended that Plaintiff Cesar F.’s motion for summary judgment (Dkt. 10) be granted and the Commissioner’s motion (Dkt. 12) be denied. It is further recommended that the decision of the Commissioner of Social Security be vacated and that this matter be remanded for further administrative proceedings.

1 Michelle King is the current acting Commissioner. But no request to substitute her has been made. 1 Background Cesar, who has a work history as a laborer and truck driver, was in a

motor vehicle accident on October 25, 2019. R.24, 28. The accident resulted in spinal injuries that led to one surgery and a recommendation for a second surgery that Cesar could not afford. R.546-49, 706-08. During this period, Cesar began developing a variety of mental health symptoms. R.709-12. Cesar

stopped working in May 2020. R.39. Cesar filed for disability insurance benefits and supplemental security income benefits on April 22, 2021, claiming a disability onset date of May 12, 2020. R.59, 68. He asserted the following impairments: depression, post-

traumatic stress disorder, cognitive impairment, and back and neck injury. R.59, 68. The Commissioner denied Cesar’s applications and a subsequent request for reconsideration. R.36, 107, 112, 117, 122, 126, 129, 133, 141. Cesar,

through his non-attorney representative, requested a telephonic hearing before an administrative law judge (“ALJ”). R.126, 144, 147, 158, 167, 177-78. At the ensuing hearing, Cesar and a vocational expert testified, and Cesar was represented by the same representative. R.36-56. After the hearing, the ALJ

issued a decision outlining his findings. R.15-35.

2 The ALJ found that Cesar met the insured status requirements and had not engaged in substantial gainful activity since the alleged onset date. R.21.

Although the ALJ found that Cesar had severe impairments—depression, neurocognitive disorder, anxiety, lumbar spine disorder, status post cervical spine fusion and right shoulder impingement—he concluded that Cesar did not have “an impairment or combination of impairments that meets or medically

equals the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1.” R.21-22. The ALJ then formulated the residual functional capacity (“RFC”), finding that Cesar

has the residual functional capacity to perform sedentary work as defined in 20 CFR 404.1567(a) and 416.967(a) except: occasional climbing of ramps, stairs; occasional stooping, kneeling, crouching, crawling, and balancing; no climbing of ladders, ropes, and scaffolding[.] [He should] avoid all exposure to unprotected heights and hazardous machinery[, and] overhead reach is limited to occasional on the right, frequent in all other directions[. He ] can understand, carry out and remember simple instructions; can respond appropriately to supervisors, coworkers, the public, usual work situations[;] and can deal with changes in a routine work setting.

R.23. The ALJ determined that, with this RFC, Cesar is unable to perform his past relevant work. R.28. But the ALJ found, in light of Cesar’s age, education, work experience, and the RFC, that there are jobs that exist in significant 3 numbers in the national economy that Cesar can perform, such as document preparer, ticket counter, or escort vehicle driver. R.29. The ALJ therefore

determined that Cesar is not disabled. R.30. Cesar unsuccessfully appealed the ALJ’s decision to the Social Security Administration Appeals Council, which rendered the decision ripe for this Court’s review. See R.1-3; 42 U.S.C. § 405(g); Sims v. Apfel, 530 U.S. 103, 106-

07 (2000) (“[Social Security Administration] regulations provide that, if ... the [Appeals] Council denies the request for review, the ALJ’s opinion becomes the final decision.”). Legal Standard

A reviewing court assesses the Commissioner’s denial of social security benefits “only to ascertain whether (1) the final decision is supported by substantial evidence and (2) whether the Commissioner used the proper legal standards to evaluate the evidence.” Whitehead v. Colvin, 820 F.3d 776, 779

(5th Cir. 2016) (per curiam) (quotation omitted). “Substantial evidence is ‘such relevant evidence as a reasonable mind might accept to support a conclusion.’” Greenspan v. Shalala, 38 F.3d 232, 236 (5th Cir. 1994) (quoting Richardson v. Perales, 402 U.S. 389, 401 (1971)). It is “more than a scintilla, but it need not

be a preponderance.” Taylor v. Astrue, 706 F.3d 600, 602 (5th Cir. 2012) (quoting Leggett v. Chater, 67 F.3d 558, 564 (5th Cir. 1995)). 4 When conducting its review, the Court cannot reweigh the evidence or substitute its judgment for the Commissioner’s. Brown v. Apfel, 192 F.3d 492,

496 (5th Cir. 1999). “Conflicts of evidence are for the Commissioner, not the courts, to resolve.” Perez v. Barnhart, 415 F.3d 457, 461 (5th Cir. 2005). But judicial review must not be “so obsequious as to be meaningless.” Brown, 192 F.3d at 496 (quotation omitted). The court must scrutinize the record as a

whole, taking into account whatever fairly detracts from the weight of evidence supporting the Commissioner’s findings. Singletary v. Bowen, 798 F.2d 818, 823 (5th Cir. 1986). Analysis

I. Legal Framework “The Commissioner uses a sequential, five-step approach to determine whether a claimant is ... disabled: (1) whether the claimant is presently performing substantial gainful activity; (2) whether the claimant has a severe

impairment; (3) whether the impairment meets or equals a listed impairment; (4) whether the impairment prevents the claimant from doing past relevant work; and (5) whether the impairment prevents the claimant from performing any other substantial gainful activity.” Morgan v. Colvin, 803 F.3d 773, 776

(5th Cir. 2015) (citing 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4)) (footnote omitted).

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Related

Brown v. Apfel
192 F.3d 492 (Fifth Circuit, 1999)
Carey v. Apfel
230 F.3d 131 (Fifth Circuit, 2000)
Perez v. Barnhart
415 F.3d 457 (Fifth Circuit, 2005)
Castillo v. Barnhart
151 F. App'x 334 (Fifth Circuit, 2005)
Audler v. Astrue
501 F.3d 446 (Fifth Circuit, 2007)
Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Uwe Taylor v. Michael Astrue, Commissioner
706 F.3d 600 (Fifth Circuit, 2012)
Joyce Jones v. Michael Astrue, Commissioner
691 F.3d 730 (Fifth Circuit, 2012)
Sims v. Apfel
530 U.S. 103 (Supreme Court, 2000)
Kenneth Morgan, Jr. v. Carolyn Colvin, Acting Cmsn
803 F.3d 773 (Fifth Circuit, 2015)
Alfred Ortiz, III v. City of San Antonio Fire Dept
806 F.3d 822 (Fifth Circuit, 2015)
Arthur Whitehead v. Carolyn Colvin, Acting Cmsnr
820 F.3d 776 (Fifth Circuit, 2016)

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