Hunt v. Commissioner of Social Security Administration

CourtDistrict Court, W.D. Oklahoma
DecidedApril 30, 2025
Docket5:24-cv-00580
StatusUnknown

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

Bluebook
Hunt v. Commissioner of Social Security Administration, (W.D. Okla. 2025).

Opinion

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

ANNA MAE SPRINGER HUNT, ) ) Plaintiff, ) ) v. ) Case No. CIV-24-580-R ) LELAND DUDEK, ) Acting Commissioner of Social ) Security,1 ) ) Defendant. )

REPORT AND RECOMMENDATION Plaintiff brings this action pursuant to 42 U.S.C. § 405(g) for judicial review of the final decision of the Commissioner of the Social Security Administration denying Plaintiff's application for benefits under the Social Security Act. The Commissioner has answered and filed a transcript of the administrative record (hereinafter TR. ____). This matter has been referred to the undersigned magistrate judge for initial proceedings consistent with 28 U.S.C. § 636(b)(1)(B)-(C). The parties have briefed their positions, and the matter is now at issue. It is recommended that the Commissioner's decision be AFFIRMED. I. PROCEDURAL BACKGROUND Plaintiff applied for supplemental security income (SSI) on May 31, 2022, alleging disability beginning January 1, 2016. The Social Security Administration denied Plaintiff's application for benefits. Following an administrative hearing, (TR. 46-79), an Administrative Law Judge (ALJ) issued an unfavorable decision. (TR. 17-38). The Appeals

1 Leland Dudek became the Acting Commissioner of Social Security Administration on February 18, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Leland Dudek should be substituted as the defendant in this suit. No further action need be taken to continue this suit by Council denied Plaintiff's request for review, (TR. 1-5), making the decision of the ALJ the final decision of the Commissioner. II. THE ADMINISTRATIVE DECISION

The ALJ followed the five-step sequential evaluation process required by agency regulations. , 431 F.3d 729, 731 (10th Cir. 2005); 20 C.F.R. § 416.920. At step one, the ALJ determined that Plaintiff did not engage in substantial gainful activity after her alleged onset date. (TR. 19). At step two, the ALJ determined Plaintiff suffers from the following severe impairments: degenerative disk disease of the lumbar spine, obesity, hypertension,

restrictive airway disease, and seronegative rheumatoid arthritis. (TR. 20). At step three, the ALJ found that Plaintiff's impairments, considered individually or in combination, did not meet or medically equal any of the presumptively disabling impairments listed at 20 C.F.R. Part 404, Subpart P, Appendix 1. (TR. 23). At step four, the ALJ concluded Plaintiff has the residual functional capacity to: [P]erform sedentary work as defined in 20 CFR 416.967(a), with the following limitations: Over the course of an 8-hour workday with standard (i.e., morning, lunch and afternoon, or the equivalent) work breaks, she can lift, carry, push and pull up to 10 pounds occasionally and smaller items such as docket files, ledgers and small tools more frequently; sit 6 hours; and stand and walk for a combined total of 2 hours; occasionally stoop, kneel, crouch, crawl and balance as those terms are defined in the Selected Characteristics of Occupations; occasionally climb ramps and stairs, but never climb ladders, ropes or scaffolds, or otherwise work at unprotected heights; tolerate occasional exposure to pulmonary irritants such as dust, fumes, odors and gases; reach, handle, and finger frequently but not constantly; cannot operate heavy machinery or perform work involving commercial driving; and can sustain attention and concentration for detailed but not complex work tasks. (TR. 24-25). The ALJ next concluded Plaintiff could not perform her past relevant work as a gambling cashier, money counter, or janitor. (TR. 36). At step five, the ALJ considered Plaintiff's age, education, work experience and

RFC and concluded there were jobs existing in significant numbers in the national economy that she could perform. (TR. 36). At the administrative hearing, the vocational expert (VE) identified three jobs from the (DOT) that Plaintiff could perform: surveillance system monitor, (DOT #379.367-010, a sedentary, unskilled job with 35,000 such jobs existing in the national economy); document preparer (DOT #249.587-018, a sedentary, unskilled job with 25,000 jobs existing in the national

economy); and addresser, (DOT #209.587-010, a sedentary, unskilled job with 2,000 of existing in the national economy). (TR. 37). The ALJ adopted the VE's testimony and concluded Plaintiff was not disabled. (TR. 38). III. ISSUES PRESENTED On appeal, Plaintiff argues: (1) the ALJ did not “understand or appreciate” the rheumatologist’s physical exam findings of “dactylitis” or “swan neck deformity,” (ECF No. 7:11-13); (2) the ALJ’s consistency evaluation did not meet the requirements of Social

Security Ruling (SSR) 16-3p, (ECF No. 7:14-25); and (3) the ALJ’s function-by-function analysis did not meet the requirements of SSR 96-8p, (ECF No. 7:25-31). IV. STANDARD OF REVIEW This Court reviews the Commissioner's final decision “to determin[e] whether the Commissioner applied the correct legal standards and whether the agency's factual findings are supported by substantial evidence.” , 952 F.3d. 1172, 1177 (10th Cir. 2020) (quoting , 756 F.3d 1171, 1175 (10th Cir. 2014)). Under the “substantial evidence” standard, a court looks to an existing

administrative record and asks whether it contains “‘sufficien[t] evidence’ to support the agency's factual determinations.” , 587 U.S. 97, 102 (2019) (alteration in original). “Substantial evidence . . . is ‘more than a mere scintilla.’ It means—and means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” at 103 (internal citation omitted) (quoting , 305 U.S. 197, 229 (1938)). While the court considers whether the ALJ

followed the applicable rules of law in weighing evidence in disability cases, the court will “neither reweigh the evidence nor substitute [its] judgment for that of the agency.” , 805 F.3d 1199, 1201 (10th Cir. 2015) (quoting 718 F.3d 1257, 1262 (10th Cir. 2013)). Nevertheless, the Court must reverse decisions if the ALJ has simply picked out and relied on evidence that supports her conclusion without discussing relevant evidence to the contrary. V. ANALYSIS

A. Plaintiff’s Dactylitis and Swan Neck Deformity Diagnoses and Pain Management Medications

Plaintiff’s hand problems began before the relevant Social Security period. Plaintiff reported an abnormal feeling in her left ring and pinky fingers in October 2021. (TR. 598). Pain management records from March 2022 show left index trigger finger without further follow-up screenings or tests, and emergency room records for an unrelated injury from April 2022—just before the beginning of the relevant period—revealed no hand deformity and full range of motion for all joints. (TR. 798 & 646-47).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Qualls v. Apfel
206 F.3d 1368 (Tenth Circuit, 2000)
Zoltanski v. Federal Aviation Administration
372 F.3d 1195 (Tenth Circuit, 2004)
Grogan v. Barnhart
399 F.3d 1257 (Tenth Circuit, 2005)
Fischer-Ross v. Barnhart
431 F.3d 729 (Tenth Circuit, 2005)
Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Casanova v. Ulibarri
595 F.3d 1120 (Tenth Circuit, 2010)
Weigel v. Astrue
425 F. App'x 706 (Tenth Circuit, 2011)
Keyes-Zachary v. Astrue
695 F.3d 1156 (Tenth Circuit, 2012)
Newbold v. Astrue
718 F.3d 1257 (Tenth Circuit, 2013)
Flaherty v. Astrue
515 F.3d 1067 (Tenth Circuit, 2008)
Knight Ex Rel. P.K. v. Colvin
756 F.3d 1171 (Tenth Circuit, 2014)
Vigil v. Colvin
805 F.3d 1199 (Tenth Circuit, 2015)
Paulsen v. Colvin
665 F. App'x 660 (Tenth Circuit, 2016)

Cite This Page — Counsel Stack

Bluebook (online)
Hunt v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hunt-v-commissioner-of-social-security-administration-okwd-2025.