Lane v. Commissioner of Social Security Administration

CourtDistrict Court, W.D. Oklahoma
DecidedSeptember 10, 2021
Docket5:20-cv-00928
StatusUnknown

This text of Lane v. Commissioner of Social Security Administration (Lane 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
Lane v. Commissioner of Social Security Administration, (W.D. Okla. 2021).

Opinion

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

LAURA MARIE LANE, ) ) Plaintiff, ) ) v. ) ) Cas e No. CIV-20-928-SM KILOLO KIJAKAZI, ) ACTING COMMISSIONER OF ) SOCIAL SECURITY ) ADMINISTRATION, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER

Laura Lane (Plaintiff) brings this action for judicial review of the Commissioner of Social Security’s final decision that she was not “disabled” under the Social Security Act. See 42 U.S.C. §§ 405(g), 423(d)(1)(A). The parties have consented to the undersigned for proceedings consistent with 28 U.S.C. § 636(c). See Docs. 19, 21.1 Plaintiff asks this Court to reverse the Commissioner’s decision and to remand the case for further proceedings, arguing the Administrative Law Judge (ALJ) erred in his (1) consideration of her medically determinable impairments when formulating her residential functional capacity; (2) step-

1 Citations to the parties’ pleadings and attached exhibits will refer to this Court’s CM/ECF pagination. Citations to the administrative record (AR) will refer to its original pagination. five findings; and (3) that the Appeals Council disregarded certain medical records. Doc. 23, at 2. After a careful review of the AR, the parties’ briefs, and

the relevant authority, the Court affirms the Commissioner’s decision finding that substantial evidence supports it and finding no legal error. See 42 U.S.C. § 405(g). I. Administrative determination. A. Disability standard.

The Social Security Act defines “disability” as the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less

than 12 months.” 42 U.S.C. § 423(d)(1)(A). “This twelve-month duration requirement applies to the claimant’s inability to engage in any substantial gainful activity, and not just [the claimant’s] underlying impairment.” Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007) (citing Barnhart v. Walton, 535

U.S. 212, 218-19 (2002)). B. Burden of proof. Plaintiff “bears the burden of establishing a disability” and of “ma[king] a prima facie showing that [s]he can no longer engage in h[er] prior work activity.” Turner v. Heckler, 754 F.2d 326, 328 (10th Cir. 1985). If Plaintiff

2 makes that prima facie showing, the burden of proof then shifts to the Commissioner to show Plaintiff retains the capacity to perform a different type

of work and that such a specific type of job exists in the national economy. Id. C. Relevant findings. 1. Administrative Law Judge’s findings. The ALJ assigned to Plaintiff’s case applied the standard regulatory analysis to decide whether Plaintiff was disabled during the relevant

timeframe. AR 21-34; see 20 C.F.R. § 404.1520(a)(4); see also Wall v. Astrue, 561 F.3d 1048, 1052 (10th Cir. 2009) (describing the five-step process). The ALJ found Plaintiff: (1) had not engaged in substantial gainful activity since her alleged onset date of June 25, 2018;

(2) had the following severe medically determinable impairments: degenerative disc disease, cervical spinal stenosis, depressive disorder, hypertension, and chronic pain syndrome;

(3) had no impairment or combination of impairments that met or medically equaled the severity of a listed impairment;

(4) had the residual functional capacity2 (RFC) to perform sedentary work, with certain restrictions and with the nonexertional limitations that she can perform tasks with

2 Residual functional capacity “is the most [a claimant] can still do despite [a claimant’s] limitations.” 20 C.F.R. § 404.1545(a)(1).

3 routine supervision, can relate to others on a superficial work basis, and she can adapt to a work situation;

(5) was not able to perform her past relevant work;

(6) was able to perform jobs that exist in the national economy, such as ticket counter, addresser, and polisher; and so,

(7) had not been under a disability from June 25, 2018 through March 2, 2020. See AR 21-34. 2. Appeals Council’s findings. The Social Security Administration’s Appeals Council denied Plaintiff’s request for review, see id. at 8-11, making the ALJ’s decision “the Commissioner’s final decision for [judicial] review.” Krauser v. Astrue, 638 F.3d 1324, 1327 (10th Cir. 2011). II. Judicial review of the Commissioner’s final decision. A. Review standard. The Court reviews the Commissioner’s final decision to determine “whether substantial evidence supports the factual findings and whether the ALJ applied the correct legal standards.” Allman v. Colvin, 813 F.3d 1326, 1330 (10th Cir. 2016). Substantial evidence is “more than a scintilla, but less than a preponderance.” Lax, 489 F.3d at 1084; see also Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (“It means—and means only—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”)

4 (internal quotation marks and citation omitted). A decision is not based on substantial evidence “if it is overwhelmed by other evidence in the record.”

Wall, 561 F.3d at 1052 (citation omitted). The Court will “neither reweigh the evidence nor substitute [its] judgment for that of the agency.” Newbold v. Colvin, 718 F.3d 1257, 1262 (10th Cir. 2013) (citation omitted). B. Issues for judicial review. 1. Substantial evidence supports the ALJ’s RFC assessment. a. The ALJ adequately considered Plaintiff’s non- severe impairments. Plaintiff’s brief presents a zig-zag litany of arguments and non- arguments. She outlines her testimony, Doc. 23, at 4, argues the ALJ did not consider her mental impairments, id. at 5, alleges the ALJ did not adequately

consider over twenty impairments, id. at 3, argues the RFC lacked any limitations on the use of her hands, id. at 6, maintains the ALJ disregarded her spine impairments, id. at 7, challenges the ALJ’s “pain analysis,” id. at 8, and argues the ALJ’s many step-two errors “prejudiced” his decisions at steps

three and four. Id. at 10. The Court addresses those claims for which Plaintiff fleshes out an argument.3 See, e.g., Mays v. Colvin, 739 F.3d 569, 576 (10th Cir. 2014) (stating that the court “will not construct an argument for” the plaintiff);

3 Plaintiff does not further develop these claims in her reply brief. Doc. 27.

5 Keyes-Zachary v. Astrue, 695 F.3d 1156, 1161 (10th Cir. 2012) (declining to consider issues not “adequately briefed” for the court’s review).

i. The RFC assessment adequately accounted for Plaintiff’s physical limitations.

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Related

Barnhart v. Walton
535 U.S. 212 (Supreme Court, 2002)
Doyal v. Barnhart
331 F.3d 758 (Tenth Circuit, 2003)
Threet v. Barnhart
353 F.3d 1185 (Tenth Circuit, 2003)
Chambers v. Barnhart
389 F.3d 1139 (Tenth Circuit, 2004)
Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Wall v. Astrue
561 F.3d 1048 (Tenth Circuit, 2009)
Krauser v. Astrue
638 F.3d 1324 (Tenth Circuit, 2011)
Keyes-Zachary v. Astrue
695 F.3d 1156 (Tenth Circuit, 2012)
Padilla v. Astrue
525 F. App'x 710 (Tenth Circuit, 2013)
Newbold v. Astrue
718 F.3d 1257 (Tenth Circuit, 2013)
Mays v. Colvin
739 F.3d 569 (Tenth Circuit, 2014)
Allman v. Colvin
813 F.3d 1326 (Tenth Circuit, 2016)
Brownrigg v. Berryhill
688 F. App'x 542 (Tenth Circuit, 2017)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)

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Lane v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lane-v-commissioner-of-social-security-administration-okwd-2021.