Jamerson v. Dudek

CourtDistrict Court, D. Nevada
DecidedFebruary 26, 2025
Docket2:24-cv-01020
StatusUnknown

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

Bluebook
Jamerson v. Dudek, (D. Nev. 2025).

Opinion

1 2 3 UNITED STATES DISTRICT COURT 4 DISTRICT OF NEVADA 5 6 SCOTT D. J., Case No. 2:24-cv-01020-NJK

7 Plaintiff(s), ORDER 8 v. [Docket No. 14] 9 LEE DUDEK, 10 Defendant(s). 11 This case involves judicial review of administrative action by the Commissioner of Social 12 Security (“Commissioner”) denying Plaintiff’s application for disability insurance benefits 13 pursuant to Title XVI of the Social Security Act. Currently before the Court is Plaintiff’s opening 14 brief seeking an award of benefits or remand. Docket No. 14. The Commissioner filed a 15 responsive brief in opposition. Docket No. 16. No reply was filed. The parties consented to 16 resolution of this matter by the undersigned magistrate judge. See Docket Nos. 3-4. 17 I. STANDARDS 18 A. Disability Evaluation Process 19 The standard for determining disability is whether a social security claimant has an 20 “inability to engage in any substantial gainful activity by reason of any medically determinable 21 physical or mental impairment which can be expected . . . to last for a continuous period of not 22 less than 12 months.” 42 U.S.C. § 423(d)(1)(A); see also 42 U.S.C. § 1382c(3)(A). That 23 determination is made by following a five-step sequential evaluation process. Bowen v. Yuckert, 24 482 U.S. 137, 140 (1987) (citing 20 C.F.R. §§ 404.1520, 416.920). The first step addresses 25 whether the claimant is currently engaging in substantial gainful activity. 20 C.F.R. §§ 26 404.1520(b), 416.920(b).1 The second step addresses whether the claimant has a medically 27 1 The five-step process is largely the same for both Title II and Title XVI claims. For a 28 Title II claim, however, a claimant must also meet insurance requirements. 20 C.F.R. § 404.130. 1 determinable impairment that is severe or a combination of impairments that significantly limits 2 basic work activities. 20 C.F.R. §§ 404.1520(c), 416.920(c). The third step addresses whether the 3 claimant’s impairments or combination of impairments meet or medically equal the criteria of an 4 impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1. 20 C.F.R. §§ 404.1520(d), 5 404.1525, 404.1526, 416.920(d), 416.925, 416.926. There is then a determination of the 6 claimant’s residual functional capacity, which assesses the claimant’s ability to do physical and 7 mental work-related activities. 20 C.F.R. §§ 404.1520(e), 416.920(e). The fourth step addresses 8 whether the claimant has the residual functional capacity to perform past relevant work. 20 C.F.R. 9 §§ 404.1520(f), 416.920(f). The fifth step addresses whether the claimant is able to do other work 10 considering the residual functional capacity, age, education, and work experience. 20 C.F.R. §§ 11 404.1520(g), 416.920(g). 12 B. Judicial Review 13 After exhausting the administrative process, a claimant may seek judicial review of a 14 decision denying social security benefits. 42 U.S.C. § 405(g). The Court must uphold a decision 15 denying benefits if the proper legal standard was applied and there is substantial evidence in the 16 record as a whole to support the decision. Webb v. Barnhart, 433 F.3d 683, 686 (9th Cir. 2005). 17 Substantial evidence is “more than a mere scintilla,” which equates to “such relevant evidence as 18 a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 587 19 U.S. 97, 103 (2019). “[T]he threshold for such evidentiary sufficiency is not high.” Id. 20 II. BACKGROUND 21 A. Procedural History 22 On August 8, 2019, Plaintiff filed an application for disability benefits with an alleged 23 onset date of January 1, 2005. See, e.g., Administrative Record (“A.R.”) 348-56, 358. On 24 September 11, 2020, Plaintiff’s application was denied initially. A.R. 168-71. On April 21, 2021, 25 Plaintiff’s claim was denied on reconsideration. A.R. 174-75. On May 12, 2021, Plaintiff filed a 26 request for a hearing before an administrative law judge. A.R. 179. On May 19, 2022, and on 27 January 25, 2023, Plaintiff, Plaintiff’s representative, and a vocational expert appeared for a 28 hearing before ALJ Kathleen Kadlec. See A.R. 53-132. On April 12, 2023, the ALJ issued an 1 unfavorable decision finding that Plaintiff had not been under a disability through the date of the 2 decision. A.R. 14-52. On April 4, 2024, the ALJ’s decision became the final decision of the 3 Commissioner when the Appeals Council denied Plaintiff’s request for review. A.R. 1-6. 4 On May 31, 2024, Plaintiff commenced this suit for judicial review. Docket No. 1. 5 B. The Decision Below 6 The ALJ’s decision followed the five-step sequential evaluation process set forth in 20 7 C.F.R. § 416.920, as well as the drug addiction and alcoholism (DAA) analysis outlined in 20 8 C.F.R. § 416.935. A.R. 19-42. At step one, the ALJ found that Plaintiff had not engaged in 9 substantial gainful activity since January 1, 2005. A.R. 20. At step two, the ALJ found that 10 Plaintiff has the following severe impairments: schizoaffective disorder, seizure disorder, 11 degenerative disc disease of the cervical spine, and substance abuse disorder. A.R. 20. At step 12 three, the ALJ found that even with substance use Plaintiff does not have an impairment or 13 combination of impairments that meets or medically equals the severity of one of the listed 14 impairments in 20 C.F.R. Part 404, Subpart P, Appendix 1. A.R. 20-22. The ALJ found that, 15 including Plaintiff’s substance use, he has the residual functional capacity to 16 perform medium work as defined in 20 CFR 416.967(c) except for the following limitations. The claimant can occasionally climb 17 ladders, ropes or scaffolds. The claimant is limited to occasional motor vehicle operation or exposure to moving mechanical parts. 18 The claimant can tolerate no unprotected heights. The claimant is limited to simple routine tasks with no more than end of day 19 production requirements. The claimant can interact with supervisors frequently and interact with coworkers and the public 20 occasionally. The claimant will be off task 15% or more of the workday due to substance abuse. 21 22 A.R. 22-30 (footnote omitted). At step four, the ALJ found Plaintiff had no past relevant work. 23 A.R. 30.

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Jamerson v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jamerson-v-dudek-nvd-2025.