Harris v. King

CourtDistrict Court, D. Utah
DecidedJanuary 8, 2025
Docket2:23-cv-00924
StatusUnknown

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

Bluebook
Harris v. King, (D. Utah 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH CENTRAL DIVISION

LEQUANTE H., REPORT AND RECOMMENDATION TO

AFFIRM THE COMMISSIONER’S Plaintiff, DECISION DENYING DISABILITY

BENEFITS v.

Case No. 2:23-cv-00924 CAROLYN W. COLVIN, Acting

Commissioner of the Social Security District Judge Dale A. Kimball Administration,

Magistrate Judge Daphne A. Oberg Defendant.

Lequante H.1 brought this action for judicial review of the denial of her application for disability insurance benefits by the Commissioner of the Social Security Administration.2 The Administrative Law Judge (“ALJ”) who addressed Ms. H.’s application determined she did not qualify as disabled.3 Ms. H. argues the ALJ erred by failing to reconcile a conflict between the vocational expert’s testimony and the Dictionary of Occupational Titles as to one of the three jobs the ALJ found she could perform.4 However, any error by the ALJ in relying on this job was harmless because the other two, unchallenged jobs exist in significant numbers in the national economy.

1 Pursuant to best practices in the District of Utah addressing privacy concerns in certain cases, including social security cases, the plaintiff is referred to by her first name and last initial only. 2 (See Compl., Doc. No. 1.) 3 (Certified Tr. of Admin. R. (“Tr.”) 15–28, Doc. No. 11.) 4 (See Opening Br. 9–15, Doc. No. 12.) Therefore, the undersigned5 recommends the district judge affirm the Commissioner’s decision. STANDARD OF REVIEW Section 405(g) of Title 42 of the United States Code provides for judicial review

of the Commissioner’s final decision. This court reviews the ALJ’s decision to determine whether substantial evidence supports his factual findings and whether he applied the correct legal standards.6 “[F]ailure 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.”7 An ALJ’s factual findings are “conclusive if supported by substantial evidence.”8 Although the evidentiary sufficiency threshold for substantial evidence is “not high,” it is “more than a mere scintilla.”9 Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”10 “The possibility of drawing two inconsistent conclusions from the evidence does not prevent an

5 This case is referred to the undersigned magistrate judge under 28 U.S.C. § 636(b)(1)(B). (Doc. No. 5.) 6 See 42 U.S.C. § 405(g); Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007). 7 Jensen v. Barnhart, 436 F.3d 1163, 1165 (10th Cir. 2005). 8 Biestek v. Berryhill, 587 U.S. 97, 102 (2019) (internal quotation marks omitted). 9 Id. at 103 (citation omitted). 10 Id. (citation omitted). administrative agency’s findings from being supported by substantial evidence.”11 And the court may not reweigh the evidence nor substitute its judgment for that of the ALJ.12 APPLICABLE LAW The Social Security Act defines “disability” as the inability “to engage in any

substantial gainful activity by reason of any medically determinable physical or mental impairment” expected to result in death or last for at least twelve consecutive months.13 An individual is considered disabled only if her impairments are so severe, she cannot perform her past work or “any other kind of substantial gainful work.”14 In determining whether a claimant qualifies as disabled, the ALJ uses a five-step sequential evaluation, considering whether: 1) the claimant is engaged in substantial gainful activity; 2) she has a severe medically determinable physical or mental impairment; 3) the impairment is equivalent to an impairment precluding substantial gainful activity (listed in the appendix of the relevant disability regulation);

4) she has the residual functional capacity to perform past relevant work; and

11 Lax, 489 F.3d at 1084 (citation omitted). 12 Langley v. Barnhart, 373 F.3d 1116, 1118 (10th Cir. 2004). 13 42 U.S.C. § 423(d)(1)(A). 14 Id. § 423(d)(2)(A). 5) she has the residual functional capacity to perform other work existing in significant numbers in the national economy, considering her age, education, and work experience.15 In the first four steps, the claimant has the burden of establishing disability.16 At step

five, the burden shifts to the Commissioner to show the claimant retains the ability to perform other work in the national economy.17 PROCEDURAL HISTORY Ms. H. applied for disability insurance benefits under Title II of the Social Security Act18 in July 2022, alleging disability beginning in December 2021.19 After a hearing, the ALJ issued a decision in August 2023 finding Ms. H. not disabled.20 At step two of the sequential evaluation, the ALJ found Ms. H. had the severe impairments of “migraine without aura, Ehlers-Danlos syndrome, non-diabetic peripheral neuropathy, right shoulder degenerative joint disease, bilateral knee osteoarthritis, myofascial pain syndrome, post-traumatic stress disorder (PTSD) and depression,” and

nonsevere impairments of carpal tunnel syndrome, prediabetes, sleep apnea,

15 See 20 C.F.R. § 404.1520(a)(4); Bowen v. Yuckert, 482 U.S. 137, 140–42 (1987); Williams v. Bowen, 844 F.2d 748, 750–51 (10th Cir. 1988). 16 Ray v. Bowen, 865 F.2d 222, 224 (10th Cir. 1989). 17 Id. 18 42 U.S.C. §§ 401–434. 19 (See Tr. 15, 287–93.) 20 (Tr. 15–28.) microvascular disease, and irritable bowel syndrome with constipation.21 At step three, the ALJ found these impairments did not meet or medically equal an impairment listing.22 The ALJ then found Ms. H. had the residual functional capacity (“RFC”)23 to perform sedentary work with limitations.24 As relevant here, the ALJ found Ms. H. was

limited to “simple work” due to physical pain, fatigue, and “mental limits.”25 At step four, the ALJ found Ms. H. unable to perform her past work.26 But at step five, after considering the testimony of a vocational expert, the ALJ found Ms. H. could perform other jobs existing in significant numbers in the national economy, including final assembler, touchup screener, and document preparer.27 Therefore, the ALJ found Ms. H. not disabled and denied her claim.28

21 (Tr. 18.) 22 (Tr. 18–20.) 23 A claimant’s RFC is the most she can do in a work setting considering her limitations. See 20 C.F.R. § 404.1545(a)(1); see also SSR 96-8p, 1996 SSR LEXIS 5, at *1–2 (July 2, 1996).

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Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Allen v. Barnhart
357 F.3d 1140 (Tenth Circuit, 2004)
Langley v. Barnhart
373 F.3d 1116 (Tenth Circuit, 2004)
Hackett v. Barnhart
395 F.3d 1168 (Tenth Circuit, 2005)
Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Stokes v. Astrue
274 F. App'x 675 (Tenth Circuit, 2008)
Rogers v. Astrue
312 F. App'x 138 (Tenth Circuit, 2009)
Raymond v. Astrue
621 F.3d 1269 (Tenth Circuit, 2009)
Lynn v. Colvin
637 F. App'x 495 (Tenth Circuit, 2016)
Evans v. Colvin
640 F. App'x 731 (Tenth Circuit, 2016)
Paulek v. Colvin
662 F. App'x 588 (Tenth Circuit, 2016)
Christopher Stanton v. Commissioner, Social Security
899 F.3d 555 (Eighth Circuit, 2018)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)

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Harris v. King, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-v-king-utd-2025.