Hernandez v. Commissioner, Social Security Administration

CourtDistrict Court, N.D. Texas
DecidedMarch 24, 2025
Docket1:24-cv-00143
StatusUnknown

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

Bluebook
Hernandez v. Commissioner, Social Security Administration, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS ABILENE DIVISION

DIANE HERNANDEZ, § § Plaintiff, § § v. § Civil Action No. 1:24-cv-00143-BP § COMMISSIONER OF § SOCIAL SECURITY, § § Defendant. § MEMORANDUM OPINION AND ORDER Diane L. Hernandez (“Hernandez”) applied for Title II Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”) under the Social Security Act (“SSA”). The Commissioner denied her application initially and upon reconsideration, deciding that she was not disabled. Hernandez appealed. There is no reversible error in the residual functional capacity (“RFC”) that the Administrative Law Judge (“ALJ”) formulated, and there is substantial evidence to support the ALJ’s findings that Hernandez was not disabled and that there were a significant number of jobs exist in the national economy that she could perform. Accordingly, the Court AFFIRMS the Commissioner’s decision and DISMISSES the case with prejudice. I. BACKGROUND Hernandez was born on January 5, 1967. Soc. Sec. Admin. R. (hereinafter “Tr.”) 32. She applied for DIB and SSI on November 4, 2021, alleging disability since April 1, 2018. ECF No. 1 at 1, Tr. 19. On the alleged disability onset date, she was closely approaching advanced age. Tr. 32. After a telephonic hearing on November 9, 2023, the ALJ denied her application for benefits in a decision dated February 21, 2024. Tr. 16-55. The Appeals Council (“AC”) denied her request for review, making the ALJ’s decision the final decision of the Commissioner. Tr. 7-11. Hernandez filed this civil action seeking judicial review under 42 U.S.C. §§ 405(g) and 1383(c). See ECF No. 1; Higginbotham v. Barnhart, 405 F.3d 332, 334 (5th Cir. 2005) (citing 20 C.F.R. § 416.1400(a)(5)) (“[T]he Commissioner’s decision does not become final until after the [AC] makes its decision denying the claimant’s request for review.”). II. STANDARD OF REVIEW

Titles II and XVI of the SSA govern the DIB program and SSI programs, respectively. See 42 U.S.C. §§ 401-434; §§1381-1383f. Claimants seeking benefits under either program must prove that they are “disabled” within the meaning of the SSA. See Hollis v. Bowen, 837 F.2d 1378, 1382 n.3 (5th Cir. 1988) (stating the “relevant law and regulations governing the determination of disability under a claim for [DIB] are identical to those governing the determination under a claim for [SSI]”). A person is disabled if he is unable “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 12 months.” 42 U.S.C. § 423(d)(1)(A), § 1382c(a)(3)(A). To determine whether a claimant is

disabled and thus entitled to benefits, the Commissioner employs a sequential five-step evaluation process. 20 C.F.R. §§ 404.1520(a), 416.920(a). First, the claimant must not be presently doing any substantial gainful activity. Id. § 404.1520(a)(4)(i). “Substantial gainful activity” is work that “involves doing significant physical or mental activities” for pay or profit. Id. § 404.1572. Second, the claimant must have a severe impairment or combination of impairments. Id. § 404.1520(a)(4)(ii). Third, disability exists if the impairment or combination of impairments meets or equals an impairment in the federal regulatory list. See 20 C.F.R. § 404.1520(a)(4)(iii) (referencing 20 C.F.R. pt. 404, subpt. P, app. 1). Before proceeding to steps four and five, the Commissioner assesses the claimant’s RFC and considers her past relevant work (“PRW”). See id. § 404.1520(a)(4), (e)-(f). RFC means “the most [a claimant] can still do despite [her] limitations.” Id. § 404.1545(a)(1). Previously, PRW meant work the claimant performed “within the past 15 years, that was substantial gainful activity, and that lasted long enough for [the claimant] to learn to do it.” Id. § 404.1560(b)(1). The definition has since changed, and as of June 22, 2024, PRW means the “work

that you have done within the past five years that was substantial gainful activity and that lasted long enough for you to learn to do it.” 20 C.F.R. § 404.1560(b)(2). The Commissioner made his decision regarding Hernandez’s application prior to June 22, 2024, so the previous definition is proper in this case. See Tr. 28. Fourth, if the claimant’s medical status alone does not constitute a disability, the impairment or impairments must prevent the claimant from returning to his PRW considering his or her RFC. Id. § 404.1520(a)(4)(iv). Fifth, the impairment must prevent the claimant from doing any other relevant work, considering the claimant’s RFC, age, work experience, and education. Id. § 404.1520(a)(4)(v); Crowley v. Apfel, 197 F.3d 194, 197-98 (5th Cir. 1999).

“A finding that a claimant is disabled or is not disabled at any point in the five-step review is conclusive and terminates the analysis.” Lovelace v. Bowen, 813 F.2d 55, 58 (5th Cir. 1987). “The claimant bears the burden of showing he is disabled through the first four steps of the analysis; on the fifth, the Commissioner must show that there is other substantial work in the national economy that the claimant can perform.” Audler v. Astrue, 501 F.3d 446, 448 (5th Cir. 2007). Judicial review is limited to determining whether the Commissioner applied correct legal standards and whether substantial evidence in the record supports the Commissioner’s decision. Leggett v. Chater, 67 F.3d 558, 564 (5th Cir. 1995); Hollis v. Bowen, 837 F.2d 1378, 1382 (5th Cir. 1988). “Substantial evidence is such relevant evidence as a reasonable mind might accept to support a conclusion.” Ripley v. Chater, 67 F.3d 552, 555 (5th Cir. 1995) (quoting Greenspan v. Shalala, 38 F.3d 232, 236 (5th Cir. 1994)). “It is more than a mere scintilla and less than a preponderance.” Boyd v. Apfel, 239 F.3d 698, 704 (5th Cir. 2001) (quoting Harris v. Apfel, 209 F.3d 413, 417 (5th Cir. 2000)). “A finding of no substantial evidence is appropriate only if no

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Related

Brown v. Apfel
192 F.3d 492 (Fifth Circuit, 1999)
Crowley v. Apfel
197 F.3d 194 (Fifth Circuit, 1999)
Harris v. Apfel
209 F.3d 413 (Fifth Circuit, 2000)
Myers v. Apfel
238 F.3d 617 (Fifth Circuit, 2001)
Boyd v. Apfel
239 F.3d 698 (Fifth Circuit, 2001)
Higginbotham v. Barnhart
405 F.3d 332 (Fifth Circuit, 2005)
Audler v. Astrue
501 F.3d 446 (Fifth Circuit, 2007)
Uwe Taylor v. Michael Astrue, Commissioner
706 F.3d 600 (Fifth Circuit, 2012)
Webster v. Kijakazi
19 F.4th 715 (Fifth Circuit, 2021)

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Hernandez v. Commissioner, Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hernandez-v-commissioner-social-security-administration-txnd-2025.