Floyd v. Commissioner of Social Security Administration

CourtDistrict Court, W.D. Texas
DecidedMarch 28, 2025
Docket3:24-cv-00045
StatusUnknown

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

Bluebook
Floyd v. Commissioner of Social Security Administration, (W.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS EL PASO DIVISION

ROUSHELL FLOYD, § § Plaintiff, § v. § EP-24-CV-00045-MAT § LELAND DUDEK, ACTING § COMMISSIONER OF THE SOCIAL § SECURITY ADMINISTRATION1, § Defendant. §

MEMORANDUM OPINION AND ORDER

Plaintiff Roushell Floyd (“Plaintiff”) appeals from a decision of the Commissioner of the Social Security Administration (“Defendant”) denying his claim for disability insurance benefits (“DIB”) under Title II of the Social Security Act. On May 6, 2024, upon consent of both parties, United States District Judge Kathleen Cardone assigned this case to the undersigned for a memorandum opinion and order pursuant to 28 U.S.C. § 636(c) and Appendix C to the Local Rules of the United States District Court for the Western District of Texas. For the following reasons, the Court ORDERS that the Commissioner’s decision be AFFIRMED pursuant to 42 U.S.C. § 405(g). I. BACKGROUND & PROCEDURAL HISTORY Plaintiff is a fifty-six-year-old man with a college education and past relevant work as a supply technician in the United States Army and hospital. Tr. of Admin. R. [hereinafter, “Tr.”] at 189, 225, 234, ECF No. 4. On June 1, 2022, Plaintiff applied for disability insurance benefits. Id. at 28. He alleged disability beginning February 28, 2022, due to neurocognitive impairment, post-

1 Leland Dudek became the Acting Commissioner of the Social Security Administration on February 17, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, “Leland Dudek, Acting Commissioner of the Social Security Administration” should be substituted for “Martin O’Malley, Commissioner of the Social Security Administration” as the defendant in this suit. traumatic stress disorder, degenerative disc disease of the lumbar spine, depressive disorder, and alcohol use disorder. See id. at 28. 30–31. At the time of the application, Plaintiff was fifty-three years old. See id. at 189, 28. On December 15, 2022, Plaintiff’s disability claims were denied, and again upon reconsideration on February 8, 2023. Id. at 28. Administrative Law Judge (“ALJ”) Michael C.

Hertzig held a telephonic hearing on August 17, 2023, and later issued a decision denying Plaintiff’s claims on August 29, 2023. Id. at 29–39. Plaintiff requested review of the ALJ’s decision, which was denied by the Appeals Council on November 1, 2023. Id. at 8–10. The ALJ’s decision became the final decision of the Commissioner at that time. Plaintiff now seeks judicial review of the decision. On appeal, Plaintiff presents two issues for the Court. First, Plaintiff alleges the ALJ erred because he rejected the medical opinions’ social interaction limitations and improperly relied on the doctors’ observations of Plaintiff’s demeanor during his medical examinations to formulate Plaintiff’s residual functional capacity (“RFC”). Pl.’s Br. at 10–16, ECF No. 8. Second, Plaintiff

maintains that the ALJ’s decision is not supported by substantial evidence because the ALJ rejected all the medical opinions and determined Plaintiff’s functional limitations off his lay interpretation of raw medical data. Id. at 16–18. For the reasons set forth below, the Court finds that the ALJ committed no legal error and affirms the ALJ’s decision.

II. DISCUSSION A. Standard of Review

Judicial review of the Commissioner’s decision is limited to a determination of whether (1) the Commissioner’s final decision is supported by substantial evidence on the record and (2) the Commissioner applied the proper legal standards. See 42 U.S.C. § 405(g); Copeland v. Colvin, 771 F.3d 920, 923 (5th Cir. 2014). “Substantial evidence is more than a scintilla, less than a preponderance, and is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Sun v. Colvin, 793 F.3d 502, 508 (5th Cir. 2015). In applying the “substantial evidence” standard, “the

court scrutinizes the record to determine whether such evidence is present,” id., but it may not “try the issues de novo” or “reweigh the evidence.” Salmond v. Berryhill, 892 F.3d 812, 817 (5th Cir. 2018). “[N]or, in the event of evidentiary conflict or uncertainty,” may the court substitute its judgment for the Commissioner's, “even if [it] believe[s] the evidence weighs against the Commissioner's decision.” Garcia v. Berryhill, 880 F.3d 700, 704 (5th Cir. 2018). “Conflicts of evidence are for the Commissioner, not the courts, to resolve.” Sun, 793 F.3d at 508. “A finding of no substantial evidence is appropriate only if no credible evidentiary choices or medical findings support the decision.” Whitehead v. Colvin, 820 F.3d 776, 779 (5th Cir. 2016). Generally, “[w]here . . . the Secretary has relied on erroneous legal standards in assessing

the evidence, he must reconsider that denial.” Leidler v. Sullivan, 885 F.2d 291, 294 (5th Cir. 1989). However, even if the ALJ commits legal error, “remand is warranted only if the . . . error was harmful.” Miller v. Kijakazi, No. 22-60541, 2023 WL 234773, at *3 (5th Cir. Jan. 18, 2023) (per curiam) (unpublished) (citing Shineski v. Sanders, 556 U.S. 396, 407–08 (2009)); see also Mays v. Bowen, 837 F.2d 1362, 1364 (5th Cir. 1988) (“Procedural perfection in administrative proceedings is not required. This court will not vacate a judgment unless the substantial rights of a party have been affected.”). “Harmless error exists when it is inconceivable that a different administrative conclusion would have been reached even if the ALJ did not err.” Keel v. Saul, 986 F.3d 551, 556 (5th Cir. 2021). Furthermore, it is plaintiff’s burden to show prejudice or harm from the error. Jones v. Astrue, 691 F.3d 730, 734–35 (5th Cir. 2012).

B. Evaluation Process

Under the Social Security Act, disability is defined as the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment … which has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A); see 42 U.S.C. § 416(i).

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