Ford v. Social Security Administration

District Court, E.D. Oklahoma·Decided September 18, 2023·No. 6:22-cv-00159·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

MAURINA JO FORD, ) ) Plaintiff, ) ) v. ) Case No. CIV-22-159-GLJ ) KILOLO KIJAKAZI, ) Acting Commissioner of the Social ) Security Administration, ) ) Defendant. ) OPINION AND ORDER Claimant Maurina Jo Ford requests judicial review of a denial of benefits by the Commissioner of the Social Security Administration pursuant to 42 U.S.C. § 405(g). She appeals the Commissioner’s decision and asserts that the Administrative Law Judge (“ALJ”) erred in determining she was not disabled. For the reasons discussed below, the Commissioner’s decision is hereby AFFIRMED. Social Security Law and Standard of Review Disability under the Social Security Act is defined as the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment[.]” 42 U.S.C. § 423(d)(1)(A). A claimant is disabled under the Social Security Act “only if [her] physical or mental impairment or impairments are of such severity that [she] is not only unable to do his previous work but cannot, considering [her] age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy[.]” 42 U.S.C. § 423(d)(2)(A). Social security regulations implement a five-step sequential process to evaluate a disability claim. See 20 C.F.R. §§ 404.1520, 416.920.1

Section 405(g) limits the scope of judicial review of the Commissioner’s decision to two inquiries: whether the decision was supported by substantial evidence and whether the correct legal standards were applied. See Hawkins v. Chater, 79 F.3d 1007, 1009 (10th Cir. 1996). Substantial evidence is “‘more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Richardson v. Perales, 402 U.S. 389, 401 (1971) (quoting Consolidated Edison Co. v.

NLRB, 305 U.S. 197, 229 (1938)). See also Clifton v. Chater, 79 F.3d 1007, 1009 (10th Cir. 1996). The Court may not reweigh the evidence or substitute its discretion for the Commissioner’s. See Casias v. Secretary of Health & Human Services, 933 F.2d 799, 800 (10th Cir. 1991). Instead, the Court must review the record as a whole, and “[t]he substantiality of the evidence must take into account whatever in the record fairly detracts

1 Step one requires the claimant to establish that she is not engaged in substantial gainful activity. Step two requires the claimant to establish that she has a medically severe impairment (or combination of impairments) that significantly limits her ability to do basic work activities. If the claimant is engaged in substantial gainful activity, or her impairments are not medically severe, disability benefits are denied. If she does have a medically severe impairment, it is measured at step three against the listed impairments in 20 C.F.R. Part 404, Subpt. P, App. 1. If the claimant has a listed (or “medically equivalent”) impairment, she is regarded as disabled and awarded benefits without further inquiry. Otherwise, the evaluation proceeds to step four, where the claimant must show that she lacks the residual functional capacity (“RFC”) to return to her past relevant work. At step five, the burden shifts to the Commissioner to show that there is significant work in the national economy that the claimant can perform, given her age, education, work experience and RFC. Disability benefits are denied if the claimant can return to any of her past relevant work or if her RFC does not preclude alternative work. See generally Williams v. Bowen, 844 F.2d 748, 750-51 (10th Cir. 1988). from its weight.” Universal Camera Corp. v. NLRB, U.S. 474, 488 (1951). See also Casias, 933 F.2d at 800-01.

Claimant’s Background Claimant was forty-one years old at the time of the administrative hearing. (Tr. 45). She completed high school, and has past work experience as a child monitor. (Tr. 47, 67). Claimant alleges an inability to work since March 1, 2020, due to limitations imposed by anxiety, panic disorder, degenerative disc disease, diabetes, rheumatoid arthritis, high cholesterol, and a neck injury. (Tr. 20, 49).

Procedural History On April 29, 2020, Claimant applied for supplemental security income benefits under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381-1385. On June 24, 2021, Administrative Law Judge (“ALJ”) Laura Roberts conducted an administrative hearing and determined Claimant was not disabled in a written decision dated July 28, 2021. (Tr. 35,

41). The Appeals Council denied review, making the ALJ’s opinion the Commissioner’s final decision for the purpose of this appeal. See 20 C.F.R. § 416.1481. Decision of the Administrative Law Judge The ALJ made her decision at step five. (Tr. 34). At step two she determined that Claimant had the severe impairments of obesity, lumbar degenerative disc disease, diabetes

mellitus type II, generalized anxiety disorder, major depressive disorder, social anxiety disorder, and hypertension, as well as the nonsevere impairments of left elbow fracture, ovarian mass, and mild degeneration of the knee, and the medically determinable impairments of rheumatoid arthritis, high cholesterol, and carpal tunnel syndrome. (Tr. 22- 23). She found at step three that Claimant did not meet any Listing. (Tr. 23). At step four she found that Claimant had the residual functional capacity (“RFC) to perform light work

except that she cannot climb ropes, ladders, or scaffolds; must avoid exposure to extreme hot, cold, or humid conditions; and can occasionally stoop, crouch, crawl, kneel, climb ramps and stairs, and balance on uneven, moving, or narrow surfaces. Additionally, she found Claimant can understand, remember, and carry out simple and detailed, but not complex, tasks and have only occasional interaction with coworkers and supervisors. Finally, she found Claimant could have no interaction with the general public, although

contact is “okay,” and that she cannot perform tandem or teamwork, but can adjust to occasional changes in work processes. (Tr. 25).2 The ALJ concluded that, although Claimant could not return to her previous work, there was work she could perform in the national economy such as small product assembler, electronic accessories assembler, and inspector packer. (Tr. 35).

Review Claimant contends that the ALJ erred by failing to properly determine her RFC and failing to properly assess her medical source evidence.

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