Kenneth Paul Hougas v. Commissioner of Social Security Administration

District Court, D. Arizona·Decided July 17, 2024·No. 3:23-cv-08572·Unknown

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Kenneth Paul Hougas, No. CV-23-08572-PCT-JAT

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 Pending before the Court is Plaintiff Kenneth Paul Hougas’ appeal from the 16 Commissioner of the Social Security Administration’s (“SSA”) final decision denying 17 social security disability benefits. (Doc. 1). The appeal is fully briefed, (Docs. 13, 18, 21), 18 and the Court now rules. 19 I. BACKGROUND 20 The issues presented in this appeal are: 21 1. Whether the ALJ failed in not fully crediting Plaintiff’s symptom testimony; 22 2. Whether the ALJ erred in finding Hypothyroidism and Oxygen-dependency to be 23 non-severe impairments and include them in the residual functional capacity 24 (“RFC”); 25 3. Whether the ALJ erred in not giving controlling weight to the opinion of Dr. Meier 26 as a treating physician; 27 4. Whether the ALJ supported her finding that Plaintiff could perform his former work; 28 and 1 5. Whether the jobs cited by the Vocational Expert (“VE”) meet the minimum 2 Significant Number of Jobs in the National Economy (“SNOJ”) threshold. (See Doc. 3 13 at 5).1 4 A. Factual Overview 5 Plaintiff was thirty-three years old on his alleged disability onset date of May 1, 6 2012. (Doc. 10-10 at 13). He has education at least through high school and reports past 7 work as a security guard, a chief security guard, a department store manager, and a stock 8 clerk. (Doc. 13 at 2). Plaintiff alleges that he suffers from degenerative disc disease, 9 osteoarthritis, sciatica, mild CHF, hypothyroidism, disfunction of his right knee and left 10 shoulder, asthma, essential hypertension, morbid obesity, and oxygen dependency. (Id.) 11 Plaintiff’s claims were initially denied after the SSA Appeals Council adopted the decision 12 of an ALJ issued December 28, 2017. (Doc. 10-10 at 13). Plaintiff appealed and the district 13 court vacated the ALJ’s decision and remanded it, indicating that the ALJ had not properly 14 considered Dr. Meier’s medical opinions. (Id.) A new hearing was held on January 9, 2023. 15 (Id.) The ALJ issued an unfavorable decision on April 12, 2023. (Id. at 28). In her decision, 16 the ALJ found that based on Plaintiff’s August 7, 2012, social security application, Plaintiff 17 has not been disabled—as defined in the Social Security Act—from August 7, 2012, 18 through the date of the decision. (Id.) Plaintiff then sought review in this Court. (Doc. 1). 19 B. The SSA’s Five-Step Evaluation Process 20 To qualify for social security disability insurance benefits, a claimant must show 21 that he “is under a disability.” 42 U.S.C. § 423(a)(1)(E). To be “under a disability,” the 22 claimant must be unable to engage in “substantial gainful activity” due to any medically 23 determinable physical or mental impairment that can be expected to result in death or that 24 has lasted or can be expected to last for a continuous period of not less than twelve months. 25 Id. § 423(d)(1). The impairment must be of such severity that the claimant cannot do his 26 previous work or any other substantial gainful work within the national economy. Id. 27 § 423(d)(2). The SSA has created a five-step sequential evaluation process for determining

28 1 The Court has reordered and reworded Plaintiff’s issues on appeal to facilitate its analysis. 1 whether an individual is disabled. See 20 C.F.R. § 404.1520(a)(1). The steps are followed 2 in order, and each step is potentially dispositive. See id. § 404.1520(a)(4). 3 At step one, the ALJ determines whether the claimant is engaging in “substantial 4 gainful activity.” Id. § 404.1520(a)(4)(i). “Substantial gainful activity” is work activity that 5 is (1) “substantial,” e.g., doing “significant physical or mental activities;” and (2) “gainful,” 6 e.g., usually done “for pay or profit.” 20 C.F.R. § 416.972(a)(b). If the claimant is engaging 7 in substantial gainful work activity, the ALJ will find the claimant is not disabled. Id. 8 § 404.1520(a)(4)(i). 9 At step two, the ALJ determines whether the claimant has “a severe medically 10 determinable physical or mental impairment” or severe “combination of impairments.” Id. 11 § 404.1520(a)(4)(ii). To be “severe,” the claimant’s impairment must “significantly limit” 12 the claimant’s “physical or mental ability to do basic work activities.” Id. § 404.1520(c). 13 If the claimant does not have a severe impairment or combination of impairments, the ALJ 14 will find the claimant is not disabled. Id. § 404.1520(a)(4)(ii). 15 At step three, the ALJ determines whether the claimant’s impairment(s) “meets or 16 equals” an impairment listed in Appendix 1 to Subpart P of 20 C.F.R. Part 404. Id. 17 § 404.1520(a)(4)(iii). If so, the ALJ will find the claimant is disabled, but if not, the ALJ 18 must assess the claimant’s RFC before proceeding to step four. Id. §§ 404.1520(a)(4)(iii), 19 404.1520(e). The claimant’s RFC is his ability to do physical and mental work activities 20 “despite [his] limitations,” based on all relevant evidence in the case record. Id. 21 § 404.1545(a)(1). To determine RFC, the ALJ must consider all the claimant’s 22 impairments, including those that are not “severe,” and any related symptoms that “affect 23 what [the claimant] can do in a work setting.” Id. §§ 404.1545(a)(1)–(2). 24 At step four, the ALJ determines whether the claimant has the RFC to perform the 25 physical and mental demands of “[his] past relevant work.” Id. §§ 404.1520(a)(4)(iv), 26 404.1520(e). “Past relevant work” is work the claimant has “done within the past 15 years, 27 that was substantial gainful activity.” Id. § 404.1560(b)(1). If the claimant has the RFC to 28 perform his past relevant work, the ALJ will find the claimant is not disabled. Id. 1 § 404.1520(a)(4)(iv). If the claimant cannot perform his past relevant work, the ALJ will 2 proceed to step five in the sequential evaluation process. 3 At step five, the last in the sequence, the ALJ considers whether the claimant “can 4 make an adjustment to other work,” considering his RFC, age, education, and work 5 experience. Id. § 404.1520(a)(v). If so, the ALJ will find the claimant not disabled. Id. If 6 the claimant cannot make this adjustment, the ALJ will find the opposite. Id. 7 C. The ALJ’s Application of the Factors 8 Here, at step one, the ALJ concluded that Plaintiff “has not engaged in substantial 9 gainful activity since May 1, 2012, the alleged onset date.” (Doc. 10-10 at 16). 10 At step two, the ALJ determined that the following impairments were “severe”: 11 morbid obesity; thyroid disorder; lumbar degenerative disc disease; asthma; right shoulder 12 degenerative joint disease; and COVID-19 infection. (Id.) The ALJ found that Plaintiff’s 13 impairments “significantly limit[ed] the ability to perform basic work activities as required 14 by SSR 85-28.” (Id.) The ALJ analyzed Plaintiff’s claimed mental impairments of 15 depression, anxiety, and opioid dependence under the broad functional areas of mental 16 functioning set out in the disability regulations for evaluating mental disorders. (Id. at 17).

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

Kenneth Paul Hougas v. Commissioner of Social Security Administration, (D. Ariz. 2024).

Kenneth Paul Hougas v. Commissioner of Social Security Administration (Kenneth Paul Hougas v. Commissioner of Social Security Administration) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

United States v. Christopher King
753 F.2d 1 (First Circuit, 1985)
Molina v. Astrue
674 F.3d 1104 (Ninth Circuit, 2012)