Heath-Fitzgerald v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedApril 16, 2025
Docket6:24-cv-00260
StatusUnknown

This text of Heath-Fitzgerald v. Social Security Administration (Heath-Fitzgerald 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
Heath-Fitzgerald v. Social Security Administration, (E.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA MATTHEW C. HEATH- ) FITZGERALD, ) ) ) Plaintiff, ) ) v. ) Case No. CIV-24-260-SPS ) LELAND DUDEK, Acting ) Commissioner of the Social ) Security Administration, ) ) Defendant. ) OPINION AND ORDER The claimant Matthew C. Heath-Fitzgerald, requests judicial review of a denial of benefits by the Commissioner of the Social Security Administration pursuant to 42 U.S.C. § 405(g). He appeals the Commissioner’s decision and asserts that the Administrative Law Judge (“ALJ”) erred in determining he 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 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[.]” Id. § 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 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.

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). Claimant’s Background Claimant was born on April 16, 1979, and was 41 years old on the alleged disability onset date. (Tr. 203). He was 45 years old at the time of the most recent administrative hearing conducted on May 2, 2024. (Tr. 1613). He has completed high school and has past relevant work

experience working as a restaurant manager, bar manager, small business owner, and information clerk. (Tr. 61, 242, 266, 1732-56). Claimant asserts he has been unable to work since of October 31, 2020. (Tr. 203). Procedural History The Court has jurisdiction under 42 U.S.C. § 405(g). Claimant applied for disability insurance benefits pursuant to Title II of the Social Security Act in 2021, alleging disability beginning on October 31, 2020. (Tr. 203). See 42 U.S.C. §§ 401-33. After early denials (Tr. 105- 08, 111-14), he requested a de novo hearing before an ALJ. (Tr. 115-16). An ALJ convened a hearing in November 2022, at which Claimant, with the assistance of non-attorney representative, and a vocational expert, appeared and testified. (Tr. 57-79). On November 28, 2022, an ALJ issued

an unfavorable decision. (Tr. 38-51). After the Appeals Council denied Claimant’s request for review, (Tr. 1-7, 187-88) Claimant then sought judicial review of the ALJ’s November 2022 decision in a complaint filed with the Court in July 2023. (Tr. 1651-54). In December 2023, on the Commissioner’s motion, the Court remanded the ALJ’s November 2022 decision for further administrative proceedings. (Tr. 1657-58). In May 2024, the ALJ convened a new hearing, at which Claimant, with the assistance of his representative, and a vocational expert, again appeared and testified. (Tr. 1613-24). On May 15, 2024, the ALJ issued a decision in which he found Claimant not disabled from the alleged onset date through the December 31, 2021, date last insured. (Tr. 1591-1606). The ALJ’s May 2024 decision became the final decision for purposes of this Court’s review on July 15, 2024. See 20 C.F.R. § 404.984. Decision of the Administrative Law Judge The ALJ made his decision at step five of the sequential evaluation. At step two, the ALJ

found that Claimant had severe impairments including diabetes mellitus type I and Grave’s disease. (Tr. 1597). The ALJ assessed Claimant suffered from some nonsevere impairments, including hypertension, tachycardia, mixed hyperlipidemia, neuropathy, restless leg syndrome, irritable bowel syndrome, GERD without esophagitis, gastritis, dental caries, migraine headaches, status post cannabinoid hyperemesis syndrome, and adjustment disorder with mixed anxiety and depressed mood. (Tr. 1597). Next, he found that Claimant’s impairments did not meet a listing. (Tr. 1599).

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Heath-Fitzgerald v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heath-fitzgerald-v-social-security-administration-oked-2025.