Lawyer v. Social Security Administration

CourtDistrict Court, N.D. Oklahoma
DecidedFebruary 28, 2025
Docket4:23-cv-00497
StatusUnknown

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

Bluebook
Lawyer v. Social Security Administration, (N.D. Okla. 2025).

Opinion

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

JERMAINE T. L., ) ) Plaintiff, ) ) v. ) ) Case No. 23-cv-00497-SH LELAND DUDEK,1 ) Acting Commissioner of Social Security, ) ) Defendant. ) OPINION AND ORDER Pursuant to 42 U.S.C. § 405(g), Plaintiff Jermaine T. L. seeks judicial review of the decision of the Commissioner of Social Security (the “Commissioner”) denying his claim for disability benefits under Title II of the Social Security Act (the “Act”), 42 U.S.C. §§ 401–434. In accordance with 28 U.S.C. § 636(c), the parties have consented to proceed before a United States Magistrate Judge. For reasons explained below, the Court reverses and remands the Commissioner’s decision denying benefits. I. Disability Determination and Standard of Review Under the Act, a “disability” is defined as an “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). The impair- ment(s) must be “of such severity that [the claimant] is not only unable to do his previous work but cannot, considering his age, education, and work experience, engage in any

1 Effective February 19, 2025, pursuant to Fed. R. Civ. P. 25(d), Leland Dudek, Acting Commissioner of Social Security, is substituted as the defendant in this action. No further action need be taken to continue this suit by reason of 42 U.S.C. § 405(g). other kind of substantial gainful work which exists in the national economy . . . .” Id. § 423(d)(2)(A). Social Security regulations implement a five-step sequential process to evaluate disability claims. 20 C.F.R. § 404.1520. To determine whether a claimant is disabled, the Commissioner inquires into: (1) whether the claimant is engaged in substantial gainful

activity; (2) whether the claimant suffers from a severe medically determinable impair- ment(s); (3) whether the impairment meets or equals a listed impairment from 20 C.F.R. Pt. 404, Subpt. P, App. 1; (4) considering the Commissioner’s assessment of the claim- ant’s residual functional capacity (“RFC”), whether the claimant can still do his past relevant work; and (5) considering the RFC and other factors, whether the claimant can perform other work. Id. § 404.1520(a)(4)(i)–(v). Generally, the claimant bears the bur- den of proof for the first four steps. Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987). At the fifth step, the burden shifts to the Commissioner to provide evidence that other work the claimant can do exists in significant numbers in the national economy. 20 C.F.R. § 404.1560(c)(2). “If a determination can be made at any of the steps that a claimant is or is not disabled, evaluation under a subsequent step is not necessary.” Williams v.

Bowen, 844 F.2d 748, 750 (10th Cir. 1988). Judicial review of the Commissioner’s final decision is limited to determining whether the Commissioner has applied the correct legal standards and whether the decision is supported by substantial evidence. See Grogan v. Barnhart, 399 F.3d 1257, 1261 (10th Cir. 2005). The “threshold for such evidentiary sufficiency is not high.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019). It is more than a scintilla but means only “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Id. (quoting Consol. Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). The Court will “meticulously examine the record as a whole, including anything that may undercut or detract from the ALJ’s findings in order to determine if the substantiality test has been met,” Grogan, 399 F.3d at 1262, but it will neither reweigh the evidence nor substitute its judgment for that of the Commissioner, Bowman v. Astrue, 511 F.3d 1270, 1272 (10th Cir. 2008). Even if a court might have reached a different conclusion, the

Commissioner’s decision stands if it is supported by substantial evidence. See White v. Barnhart, 287 F.3d 903, 908 (10th Cir. 2002). II. Background and Procedural History Plaintiff applied for Title II disability benefits on March 21, 2022. (R. 197–98.) In his application, Plaintiff alleged he has been unable to work since March 5, 2021, due to conditions including posttraumatic stress disorder (“PTSD”), anxiety, and depression. (R. 197, 221.) Plaintiff was 43 years old at the time of the Administrative Law Judge’s (“ALJ”) decision. (R. 28, 197.) Plaintiff has a college education and past relevant work as a police officer and scientific helper. (R. 222, 60.) Plaintiff’s claim was denied initially and upon reconsideration. (R. 87–95, 98– 106.) Plaintiff then requested and received a hearing before an ALJ. (R. 107–08, 33–64.) The ALJ denied benefits and found Plaintiff not disabled. (R. 17–28.) The Appeals

Council denied review on September 19, 2023 (R. 1–5), rendering the Commissioner’s decision final, 20 C.F.R. § 404.981. Plaintiff now appeals. III. The ALJ’s Decision In her decision, the ALJ found Plaintiff met the insured requirements for Title II purposes through December 31, 2026. (R. 19.) The ALJ then found at step one that Plaintiff had not engaged in substantial gainful activity since the alleged onset date. (Id.) At step two, the ALJ found Plaintiff to have the following severe impairments: (1) major depressive disorder; (2) generalized anxiety disorder; and (3) PTSD. (Id.) At step three, the ALJ found Plaintiff’s impairments did not meet or equal a listed impairment. (R. 20– 21.) The ALJ then determined that Plaintiff had the RFC to perform a full range of work at all exertional levels with the following mental limitations:

[Claimant] is able to understand, remember, and perform simple and some complex tasks, sustain attention and concentration for up to 2 hours at a time with routine breaks when performing simple and some complex tasks, and sustain the mental demands associated with performing simple and some complex tasks throughout an ordinary workday and workweek. He is able to interact with supervisors as needed to receive work instructions but would work best in a job where he has limited contact with supervisors and co-workers meaning that the individual can frequently work alone. The job should not involve interacting with the public. (R. 21.) The ALJ provided a recitation of the evidence that went into this finding. (R.

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Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Allen v. Barnhart
357 F.3d 1140 (Tenth Circuit, 2004)
Hardman v. Barnhart
362 F.3d 676 (Tenth Circuit, 2004)
Grogan v. Barnhart
399 F.3d 1257 (Tenth Circuit, 2005)
Haga v. Barnhart
482 F.3d 1205 (Tenth Circuit, 2007)
Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Bowman v. Astrue
511 F.3d 1270 (Tenth Circuit, 2008)
White v. Barnhart
287 F.3d 903 (Tenth Circuit, 2002)
Keyes-Zachary v. Astrue
695 F.3d 1156 (Tenth Circuit, 2012)
Richards v. Colvin
640 F. App'x 786 (Tenth Circuit, 2016)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)

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Lawyer v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lawyer-v-social-security-administration-oknd-2025.