Gallegos v. Social Security Administration

CourtDistrict Court, D. New Mexico
DecidedApril 18, 2022
Docket1:20-cv-00634
StatusUnknown

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

Bluebook
Gallegos v. Social Security Administration, (D.N.M. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

DANIEL V. GALLEGOS,

Plaintiff,

vs. No. 1:20-CV-00634-WJ-KRS

KILOLO KIJAKAZI, Acting Commissioner of Social Security,

Defendant.

PROPOSED FINDINGS AND RECOMMENDED DISPOSITION

Plaintiff Daniel V. Gallegos, appearing pro se, seeks review of the Commissioner’s determination that he is not entitled to disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. §§ 401-434. On March 29, 2021, in accordance with 28 U.S.C. § 636(b)(1)(B), (b)(3), this case was referred to United States Magistrate Judge Kevin R. Sweazea to conduct any necessary hearings and to recommend an ultimate disposition. (See Doc. 19) (Order of Reference). Having considered Plaintiff’s Motion to Reverse or Remand (Doc. 28), filed November 5, 2021; the Commissioner’s response in opposition (Doc. 34), filed March 9, 2022; and Plaintiff’s reply brief (Doc. 35), filed April 11, 2022,1 the undersigned RECOMMENDS that the Court DENY Plaintiff’s motion for the reasons set forth below. I. PROCEDURAL BACKGROUND On October 10, 2017, Plaintiff filed an initial application for disability insurance benefits. (See Administrative Record (“AR”) at 88).2 Plaintiff alleged he had become disabled on

1 Plaintiff’s reply was filed well beyond the March 23, 2022 deadline for doing so (see Doc. 32), and Plaintiff offers no explanation for the belated filing. Nor has Plaintiff sought an extension of the filing deadline. Nevertheless, in the interests of justice, the undersigned has considered and addressed the arguments raised in that filing. 2 Plaintiff asserts in his reply brief that he filed his claim on December 2, 2016. (See Doc. 35 at 1, 3). That is not accurate. (See AR at 42) (ALJ decision noting application date of October 10, 2017); (id. at 88, 124) (same as to notices of disability determination); (see also id. at 200-03) (October 12, 2017 notice of receipt of claim). Plaintiff December 2, 2016, due to a head injury, headaches, lower back pain, neck pain, seizures, loss of hearing, trembling in his hands, memory loss, equilibrium issues, soreness relating to a fall, anxiety, and high blood pressure. (See id. at 89-90). His application was denied at the initial level on February 22, 2018 (id. at 88), and at the reconsideration level on June 4, 2018 (id. at 124). Plaintiff requested a hearing (see id. at 143-45), which ALJ Cole Gerstner conducted on June 13,

2019 (id. at 61-87). Plaintiff was represented by counsel and testified at the hearing (id. at 64- 82), as did a vocational expert (the “VE”) (id. at 66, 82-86). On August 23, 2019, the ALJ issued his decision finding that Plaintiff was not disabled under the relevant sections of the Social Security Act. (Id. at 42-54). On May 4, 2020, the Appeals Council denied Plaintiff’s request for review (id. at 1-4), which made the ALJ’s decision the final decision of the Commissioner. In denying the request for review, the Appeals Council declined to consider additional evidence—specifically, medical records from Plaintiff’s providers post-dating the ALJ’s decision—as not relating to the period at issue and not affecting the outcome of his claim. (See id. at 2); (see also id. at 7-32, 35-38) (evidence rejected by

Appeals Council). On July 1, 2020, Plaintiff filed the complaint in this case seeking review of the Commissioner’s decision. (Doc. 1). II. LEGAL STANDARDS A. Standard of Review Judicial review of the Commissioner’s decision is limited to determining “whether substantial evidence supports the factual findings and whether the ALJ applied the correct legal standards.” Allman v. Colvin, 813 F.3d 1326, 1330 (10th Cir. 2016); see also 42 U.S.C. § 405(g). If substantial evidence supports the ALJ’s findings and the correct legal standards were applied,

appears to have mistakenly conflated his application date with his alleged onset date of December 2, 2016. (See, e.g., id. at 42, 88, 90, 106, 124). the Commissioner’s decision stands, and the plaintiff is not entitled to relief. See, e.g., Langley v. Barnhart, 373 F.3d 1116, 1118 (10th Cir. 2004). Although a court must meticulously review the entire record, it may neither reweigh the evidence nor substitute its judgment for that of the Commissioner. See, e.g., id. (quotation omitted). Substantial evidence is “such relevant evidence as a reasonable mind might accept as

adequate to support a conclusion.” See Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (quotation omitted); Langley, 373 F.3d at 1118 (quotation omitted). Although this threshold is “not high,” evidence is not substantial if it is “a mere scintilla,” Biestek, 139 S. Ct. at 1154 (quotation omitted); “if it is overwhelmed by other evidence in the record,” Langley, 373 F.3d at 1118; or if it “constitutes mere conclusion,” Grogan v. Barnhart, 399 F.3d 1257, 1261-62 (10th Cir. 2005) (quotation omitted). Thus, the Court must examine the record as a whole, “including anything that may undercut or detract from the ALJ’s findings in order to determine if the substantiality test has been met.” Grogan, 399 F.3d at 1262. While an ALJ need not discuss every piece of evidence, “[t]he record must demonstrate that the ALJ considered all of the

evidence,” and “a minimal level of articulation of the ALJ’s assessment of the evidence is required in cases in which considerable evidence is presented to counter the agency’s position.” Clifton v. Chater, 79 F.3d 1007, 1009-10 (10th Cir. 1996). “Failure to apply the correct legal standard or to provide this court with a sufficient basis to determine that appropriate legal principles have been followed is grounds for reversal.” Byron v. Heckler, 742 F.2d 1232, 1235 (10th Cir. 1984) (quotation omitted). B. Disability Framework “Disability,” as defined by the Social Security Act, is 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 twelve months.” 42 U.S.C. § 423(d)(1)(A). The Social Security Administration (“SSA”) has devised a five-step sequential evaluation process to determine disability. See Barnhart v. Thomas, 540 U.S. 20, 24 (2003); Wall v. Astrue, 561 F.3d 1048, 1051-52 (10th Cir. 2009); 20 C.F.R. §§ 404.1520, 416.920. If a finding of disability or

non-disability is directed at any point, the SSA will not proceed through the remaining steps. Thomas, 540 U.S. at 24. At the first three steps, the ALJ considers the claimant’s current work activity and the severity of his impairment or combination of impairments. See id. at 24-25.

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Gallegos v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gallegos-v-social-security-administration-nmd-2022.