Jewell v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedJuly 30, 2024
Docket6:23-cv-00148
StatusUnknown

This text of Jewell v. Social Security Administration (Jewell 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
Jewell v. Social Security Administration, (E.D. Okla. 2024).

Opinion

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

EMILY D. JEWELL, ) ) Plaintiff, ) ) v. ) Case No. 23-CV-148-GLJ ) MARTIN O’MALLEY,1 ) Commissioner of the Social ) Security Administration ) ) Defendant. )

OPINION AND ORDER

Claimant Emily D. Jewell requests judicial review of a denial of benefits by the Commissioner of the Social Security Administration pursuant to 42 U.S.C. § 405(g). She appeals the Commissioner’s decision and asserts that the Administrative Law Judge (“ALJ”) erred in determining she 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 h[er] physical or mental impairment or impairments are of such severity that

1 On December 20, 2023, Martin J. O’Malley became the Commissioner of Social Security. In accordance with Fed. R. Civ. P. 25(d), Mr. O’Malley is substituted for Kilolo Kijakazi as the Defendant in this action. [s]he is not only unable to do [her] previous work but cannot, considering h[er] age, education, and work experience, engage in any other kind of substantial gainful work which

exists in the national economy[.]” 42 U.S.C. § 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, 416.920.2 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 the correct legal standards were applied. See Clifton v. Chater, 79 F.3d 1007, 1009 (10th

Cir. 1996). 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 Consol. Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). See also Clifton, 79 F.3d at 1009. The Court may not reweigh the evidence or substitute its discretion for the Commissioner’s. See Casias v. Sec’y of

Health & Hum. Servs., 933 F.2d 799, 800 (10th Cir. 1991). Instead, the Court must review

2 Step one requires the claimant to establish that she is not engaged in substantial gainful activity. Step two requires the claimant to establish that she has a medically severe impairment (or combination of impairments) that significantly limits her ability to do basic work activities. If the claimant is engaged in substantial gainful activity, or her impairment is not medically severe, disability benefits are denied. If she 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, she is regarded as disabled and awarded benefits without further inquiry. Otherwise, the evaluation proceeds to step four, where the claimant must show that she lacks the residual functional capacity (“RFC”) to return to her past relevant work. At step five, the burden shifts to the Commissioner to show that there is significant work in the national economy that the claimant can perform, given her age, education, work experience and RFC. Disability benefits are denied if the claimant can return to any of her past relevant work or if her RFC does not preclude alternative work. See generally Williams v. Bowen, 844 F.2d 748, 750-51 (10th Cir. 1988). the record as a whole, and “[t]he substantiality of the evidence must take into account whatever in the record fairly detracts from its weight.” Univ. Camera Corp. v. NLRB, 340

U.S. 474, 488 (1951). See also Casias, 933 F.2d at 800-01. Claimant’s Background Claimant was twenty-seven years old at the time of the administrative hearing. (Tr. 55, 250). She completed high school and has past relevant work as a housekeeper. (Tr. 59, 320). Claimant alleges an onset date of October 3, 2019, due to limitations imposed by seizures and the frequent dislocation of her knees. (Tr. 266, 319).

Procedural History On June 8, 2021, Claimant protectively applied for disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. §§ 401-434, as well as supplemental security income benefits under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381- 85. (Tr. 250-62, 266-69). On October 6, 2022, ALJ Doug Gabbard, II, held an

administrative hearing and determined Claimant was not disabled on October 19, 2022. (Tr. 31-78). The Appeals Council denied review, making the ALJ’s opinion the Commissioner’s final decision for purposes of this appeal. (Tr. 1-7); See 20 C.F.R. § 404.971. Decision of the Administrative Law Judge

The ALJ made his decision at step four of the sequential evaluation. (Tr. 33-34). At step one the ALJ found Claimant had engaged in substantial gainful activity between Claimant’s alleged onset date of October 3, 2019, and April 2020; however, the ALJ concluded there had been a continuous 12-month period after April 2020 during which Claimant did not engage in substantial gainful activity. (Tr. 33-34). At step two, he determined that Claimant had the severe impairments of arthritis, idiopathic seizures,

chronic pain secondary to bilateral knee chondromalacia patellae and dislocation, depressive/bipolar disorder, and anxiety/obsessive disorder. (Tr. 34). He found at step three that Claimant did not meet any Listing. (Tr. 34-37). At step four, he found Claimant had the residual functional capacity (“RFC”) to perform light work except that she could not climb ladders/ropes/scaffolds and must avoid hazards such as open flames, unprotected heights, and dangerous moving machinery. (Tr. 38). Due to psychologically-based

limitations, the ALJ found Claimant could perform simple work, involving only one- or two-step non-detailed tasks, and engage in occasional contact with supervisors, coworkers, and the general public, but would work best alone and tolerate only occasional well- explained work place changes. (Tr. 38). The ALJ also found Claimant would need regular work breaks every two hours and could not perform fast-paced work. (Tr. 38). The ALJ

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Jewell v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jewell-v-social-security-administration-oked-2024.