Harden v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedOctober 13, 2023
Docket6:22-cv-00202
StatusUnknown

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

Bluebook
Harden v. Social Security Administration, (E.D. Okla. 2023).

Opinion

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

ROBERT JOE HARDEN, ) ) Plaintiff, ) v. ) Case No. CIV–22–202–JAR ) KILO KIJAKAZI, ) Acting Commissioner of the ) Social Security Administration, ) ) Defendant. ) OPINION AND ORDER Plaintiff Robert Joe Harden (the “Claimant”) requests judicial review of the decision of the Commissioner of the Social Security Administration (the “Commissioner”) denying Claimant’s application for disability benefits under the Social Security Act. Claimant appeals the decision of the Administrative Law Judge (“ALJ”) and asserts that the Commissioner erred because the ALJ incorrectly determined that Claimant was not disabled. For the reasons discussed below, it is the finding of this Court that the Commissioner’s decision should be and is 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 his physical or mental impairment or impairments are of such severity that he is not only unable to do his previous work but cannot, considering his 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 correct legal standards were applied. See Hawkins v. Chater, 113 F.3d 1162, 1164 (10th Cir. 1997). 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

1 Step one requires the claimant to establish that he is not engaged in substantial gainful activity. Step two requires the claimant to establish that he has a medically severe impairment (or combination of impairments) that significantly limits his ability to do basic work activities. If the claimant is engaged in substantial gainful activity, or his impairment is not medically severe, disability benefits are denied. If he 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, he is regarded as disabled and awarded benefits without further inquiry. Otherwise, the evaluation proceeds to step four, where the claimant must show that he lacks the residual functional capacity (“RFC”) to return to his past relevant work. At step five, the burden shifts to the Commissioner to show there is significant work in the national economy that the claimant can perform, given his age, education, work experience, and RFC. Disability benefits are denied if the claimant can return to any of his past relevant work or if his RFC does not preclude alternative work. See generally Williams v. Bowen, 844 F.2d 748, 750-51 (10th Cir. 1988). 799, 800 (10th Cir. 1991). But the Court must review the record as a whole, and “[t]he substantiality of evidence must take into account whatever in the record fairly detracts from its weight.” Universal Camera Corp. v. NLRB, 340 U.S. 474, 488 (1951); see also Casias, 933 F.2d at 800–01.

Claimant’s Background The claimant was forty-one years old at the time of the administrative hearing. (Tr. 1083). He possesses at least a high school education. (Tr. 1069). He has worked as a machine-shop supervisor, material handler, forklift operator, and welder’s helper. (Tr. 1068). Claimant alleges that he has been unable to work since May 23, 2013,2 due to limitations resulting from “failed lower back surgery,” pain and deterioration in hips; arthritis in spine, hips, knees, hands, and wrists; chronic exhaustion; and inability to lift and bend (Tr. 1123–1124).

Procedural History On August 11, 2016, Claimant protectively filed for disability insurance benefits pursuant to Title II (42 U.S.C. § 401, et seq.) of the Social Security Act. Claimant’s application was denied initially and upon reconsideration. After an administrative hearing, Administrative Law Judge Doug Gabbard, II, issued an unfavorable decision on December 4, 2017. Appeals Council, on review, vacated the decision and remanded the case. After a second administrative hearing, Administrative Law Judge Michael Mannes (“ALJ”) again issued an unfavorable

decision on February 18, 2020. This Court granted the Social Security

2 Although Claimant initially alleged an onset date of February 6, 2015, he subsequently amended his alleged onset date to May 23, 2013. (Tr. 1043). Administration’s unopposed motion to remand the case. While Claimant’s appeal of the ALJ’s decision to this Court was pending, he protectively filed for supplemental security income pursuant to Title XVI (42 U.S.C. § 1381, et seq.) of the Social Security Act on April 17, 2020. The Appeals Council issued an order

accompanying this Court’s order remanding the case for further proceedings and consolidating the two claims. After another administrative hearing, ALJ Mannes issued an unfavorable decision on April 29, 2022. Appeals Council denied review, so the ALJ’s written opinion is the Commissioner’s final decision for purposes of this appeal. See 20 C.F.R. § 416.1481. Decision of the Administrative Law Judge The ALJ made his decision at step five of the sequential evaluation. He determined that while Claimant suffered from severe impairments, he retained

the residual functional capacity (“RFC”) to perform sedentary work with limitations. Error Alleged for Review Claimant asserts the ALJ committed error in improperly assigning jobs which required a reasoning level above Claimant’s assigned RFC and thus

improperly determined representative jobs existed in significant numbers in the regional and national economies.

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Harden v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harden-v-social-security-administration-oked-2023.