Lewis v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedMarch 12, 2024
Docket6:23-cv-00022
StatusUnknown

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

Opinion

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

MOSE RAY LEWIS, ) ) Plaintiff, ) ) v. ) Case No. 23-cv-22-DES ) MARTIN O’MALLEY, 1 ) Commissioner of Social Security, ) ) Defendant. )

OPINION AND ORDER Pursuant to 42 U.S.C. § 405(g), Plaintiff Mose Ray Lewis (“Claimant”) seeks judicial review of a final decision by the Commissioner of the Social Security Administration (“Commissioner”) denying his claim for supplemental security income benefits under Title XVI of the Social Security Act (the “Act”). For the reasons explained below, the Court REVERSES and REMANDS the Commissioner’s decision denying benefits. I. Statutory Framework and Standard of Review The 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). To be deemed disabled under the Act, a claimant’s impairment(s) must be “of such severity that he is not only unable to do his previous work but cannot, considering his 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).

1 Effective December 20, 2023, Martin O’Malley, Commissioner of Social Security, is substituted as the defendant in this action pursuant to Fed. R. Civ. P. 25(d). No further action is necessary to continue this suit by reason of 42 U.S.C. § 405(g). Social security regulations implement a five-step sequential process to evaluate a disability claim. 20 C.F.R. § 416.920(a)(4). This process requires the Commissioner to consider: (1) whether the claimant is engaged in substantial gainful activity; (2) whether the claimant suffers from a medically determinable severe impairment(s); (3) whether such impairment meets or medically equals a listed impairment set forth in 20 C.F.R. pt. 404, subpt.

P., app. 1; (4) whether the claimant can perform her past relevant work considering the Commissioner’s assessment of the claimant’s residual functional capacity (“RFC”); and (5) whether the claimant can perform other work considering the RFC and certain vocational factors. 20 C.F.R. § 416.920(a)(4)(i)-(v). The claimant bears the burden of proof through step four, but the burden shifts to the Commissioner at step five. Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007). If it is determined, at any step of the process, that the 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). A district court’s review of the Commissioner’s final decision is governed by 42 U.S.C.

§ 405(g). The scope of judicial review under § 405(g) is limited to determining whether the Commissioner applied the correct legal standards and whether the Commissioner’s factual findings are supported by substantial evidence. See Noreja v. Soc. Sec. Comm’r, 952 F.3d 1172, 1177 (10th Cir. 2020). Substantial evidence is more than a scintilla but means only “‘such evidence as a reasonable mind might accept as adequate to support a conclusion.’” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938). In conducting its review, the Court “may neither reweigh the evidence nor substitute [its] judgment for that of the agency.” Noreja, 952 F.3d at 1178 (quotation omitted). Rather, the Court must “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.” Flaherty v. Astrue, 515 F.3d 1067, 1070 (10th Cir. 2007) (quotation omitted). II. Claimant’s Background and Procedural History In October 2020, Claimant applied for disability insurance benefits under Title II and supplemental security income benefits under Title XVI of the Act.2 (R. 217-24). Claimant

alleges he has been unable to work since an amended onset date of October 23, 2020, due to blindness/low vision, diabetes, neuropathy, and low back problems. (R. 42-43, 247). Claimant was 48 years old on the date of the ALJ’s decision. (R. 32, 217, 219). He has a high school education and past work as a cement mason. (R. 45, 63). Claimant’s claim for benefits was denied initially and on reconsideration, and he requested a hearing. (R. 71-83, 98-115, 150-51). ALJ Kimani R. Eason conducted an administrative hearing and issued a decision on July 15, 2022, finding Claimant not disabled. (R. 16-32, 38-69). The Appeals Council denied review on November 14, 2022 (R. 1-6), rendering the Commissioner’s decision final. 20 C.F.R. § 416.1481. Claimant filed this appeal

on January 13, 2023. (Docket No. 2). III. The ALJ’s Decision In his decision, the ALJ found at step one that Claimant had not engaged in substantial gainful activity since the amended alleged onset date of October 23, 2020. (R. 19). At step two, the ALJ found Claimant had the severe impairments of disorder of the spine, diabetes mellitus with retinopathy and neuropathy, and hypertension, but that his gastroesophageal reflux disease, hyperlipidemia, and anxiety were non-severe. (R. 19-24). At step three, the ALJ found Claimant’s impairments did not meet or equal a listed impairment. (R. 24-26).

2 At the administrative hearing, Claimant amended his alleged onset date to his date of filing and dismissed his application for disability insurance benefits under Title II of the Act. (R. 42-43). Before proceeding to step four, the ALJ determined Claimant had the RFC to perform a range of light work as defined in 20 C.F.R. § 416.967(b) with the following non-exertional limitations: The claimant can occasionally climb, balance, stoop, kneel, crouch and crawl. He can never work at unprotected heights or around moving mechanical parts. The claimant can never operate heavy equipment. He must avoid all exposure to open flames and open bodies of water.

(R. 27). The ALJ provided a summary of the evidence that went into this finding. (R. 27-30). At step four, the ALJ concluded that Claimant could not return to his past relevant work. (R. 30). Based on the testimony of a vocational expert (“VE”), however, the ALJ found at step five that Claimant could perform other work existing in significant numbers in the national economy, including cafeteria attendant, fast food worker, cleaner/housekeeper, document preparer, office helper, and addresser. (R. 31).

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Bluebook (online)
Lewis v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lewis-v-social-security-administration-oked-2024.