Lance v. Social Security Administration, Commissioner of

CourtDistrict Court, D. Kansas
DecidedMarch 31, 2022
Docket6:20-cv-01287
StatusUnknown

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

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Lance v. Social Security Administration, Commissioner of, (D. Kan. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF KANSAS

K.L.,1

Plaintiff,

v. Case No. 20-1287-DDC

KILOLO KIJAKAZI, Acting Commissioner of the Social Security Administration,

Defendant. ____________________________________

MEMORANDUM AND ORDER Plaintiff K.L. seeks judicial review under 42 U.S.C. § 405(g) of the final decision by the Commissioner of the Social Security Administration denying her claim for Disability Insurance Benefits under Title II of the Social Security Act, as amended. Plaintiff has filed a brief asking the court to reverse the Commissioner’s decision denying her claim and to remand her claim to the Commissioner for a new hearing before an administrative law judge (“ALJ”). Doc. 15 at 15. The Commissioner has filed a response brief, opposing plaintiff’s request for judicial review and asking the court to affirm the Commissioner’s decision. Doc. 16 at 18. This matter ripened for decision when plaintiff filed a reply brief on July 6, 2021. Doc. 17. Having reviewed the administrative record and the parties’ briefs, the court affirms the Commissioner’s decision denying plaintiff benefits. The court explains why, below.

1 The court makes all its Memoranda and Orders available online. Therefore, as part of the court’s efforts to preserve the privacy interests of Social Security disability claimants, it has decided to caption such opinions using only plaintiff’s initials. I. Background On July 2, 2018, plaintiff applied for Disability Insurance Benefits under Title II of the Social Security Act. Doc. 13 at 199–201 (AR 195–97). She alleged disability beginning on September 1, 2015, based on peripheral neuropathy, lumbar spondylosis, degenerative disc disease, developing tunnel vision, anxiety, and migraines. Id. at 122, 199 (AR 118, 195). The

Commissioner denied plaintiff’s claim initially on November 19, 2018, id. at 122–26 (AR 118– 22), and again denied the claim upon reconsideration on April 2, 2019, id. at 128–37 (AR 124– 33). Plaintiff then requested a hearing before an ALJ. Id. at 138 (AR 134). The ALJ conducted a hearing on February 4, 2020, where plaintiff appeared and testified. Id. at 33, 38–54 (AR 29, 34–50). On March 23, 2020, the ALJ issued a written decision concluding that plaintiff was not disabled, as the Social Security Act defines that term, from September 1, 2015, to the decision’s date. Id. at 16–26 (AR 12–22). Importantly, the ALJ noted that on March 21, 2018, another ALJ considering plaintiff’s earlier claim for Disability Insurance Benefits, had found that plaintiff

was not disabled, as the Social Security Act defines that term, from September 1, 2015, to that decision’s date. Id. at 16 (AR 12). Thus, the ALJ concluded, that decision was res judicata for the period of September 1, 2015, to March 21, 2018. Id. And so, the ALJ noted that her decision “only consider[ed] the time period from March 21, 2018 forward.” Id. Plaintiff then filed an appeal with the Appeals Council of the Social Security Administration. Id. at 195–98 (AR 191–94). On August 17, 2020, the Appeals Council denied plaintiff’s request for review. Id. at 5–10 (AR 1–6). Having exhausted the proceedings before the Commissioner, plaintiff now seeks judicial review and reversal of the final decision denying her Disability Insurance Benefits. II. Legal Standard A. Standard of Review Section 405(g) of Title 42 of the United States Code grants federal courts authority to conduct judicial review of final decisions of the Commissioner and “enter, upon the pleadings and transcript of the record, a judgment affirming, modifying, or reversing the decision . . . with

or without remanding the cause for a rehearing.” 42 U.S.C. § 405(g). Judicial review of the Commissioner’s denial of benefits is limited to this question: Whether substantial evidence in the record supports the factual findings and whether the Commissioner applied the correct legal standards. Noreja v. Comm’r, SSA, 952 F.3d 1172, 1177 (10th Cir. 2020); see also Mays v. Colvin, 739 F.3d 569, 571 (10th Cir. 2014); 42 U.S.C. § 405(g). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion” but it is “more than a mere scintilla[.]” Noreja, 952 F.3d at 1178 (quotation cleaned up). While the court “consider[s] whether the ALJ followed the specific rules of law that must be followed in weighing particular types of evidence in disability cases,” it

neither reweighs the evidence nor substitutes its judgment for the Commissioner’s. Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007) (quotation cleaned up). But the court also does not accept “the findings of the Commissioner” mechanically or affirm those findings “by isolating facts and labeling them substantial evidence, as the court must scrutinize the entire record in determining whether the Commissioner’s conclusions are rational.” Alfrey v. Astrue, 904 F. Supp. 2d 1165, 1167 (D. Kan. 2012). When the court decides whether substantial evidence supports the Commissioner’s decision, it “examine[s] the record as a whole, including whatever in the record fairly detracts from the weight of the Commissioner’s decision[.]” Id. “‘Evidence is not substantial if it is overwhelmed by other evidence in the record or constitutes mere conclusion.’” Noreja, 952 F.3d at 1178 (quoting Grogan v. Barnhart, 399 F.3d 1257, 1261–62 (10th Cir. 2005)). Failing “to apply the proper legal standard may be sufficient grounds for reversal independent of the substantial evidence analysis.” Brown ex rel. Brown v. Comm’r of Soc. Sec., 311 F. Supp. 2d 1151, 1155 (D. Kan. 2004) (citing Glass v. Shalala, 43 F.3d 1392, 1395 (10th

Cir. 1994)). But such a failure justifies reversal only in “‘appropriate circumstances’”—applying an improper legal standard does not require reversal in all cases. Hendron v. Colvin, 767 F.3d 951, 954 (10th Cir. 2014) (quoting Glass, 43 F.3d at 1395); accord Lee v. Colvin, No. 12-2259- SAC, 2013 WL 4549211, at *5 (D. Kan. Aug. 28, 2013) (discussing the general rule set out in Glass). Some errors are harmless and require no remand or further consideration. See, e.g., Mays, 739 F.3d at 578–79; Keyes-Zachary v. Astrue, 695 F.3d 1156, 1161–63 (10th Cir. 2012); Howard v. Barnhart, 379 F.3d 945, 947 (10th Cir. 2004). B. Disability Determination Claimants seeking Disability Insurance Benefits bear the burden to show that they are

disabled. Wall v. Astrue, 561 F.3d 1048, 1062 (10th Cir. 2009).

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