Lohmar v. Commissioner, Social Security Administration

CourtDistrict Court, N.D. Texas
DecidedNovember 14, 2024
Docket3:24-cv-00779
StatusUnknown

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

Bluebook
Lohmar v. Commissioner, Social Security Administration, (N.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS DALLAS DIVISION DELLYN L.,1 § § Plaintiff, § § v. § § Civil Action No. 3:24-CV-00779-BU COMMISSIONER, SOCIAL § SECURITY ADMINISTRATION, § § Defendant. § §

MEMORANDUM OPINION AND ORDER Plaintiff Dellyn Lohmar seeks judicial review of a final adverse decision of the Commissioner of Social Security (Commissioner) under 42 U.S.C. § 405(g). Dkt. No. 1. This case was automatically referred to the undersigned with a designation to exercise the district court’s full jurisdiction and conduct all proceedings in this case upon the consent of the parties. See Special Order No. 3-350. Both parties have since consented to proceed before a magistrate judge. See Dkt. Nos. 4, 8. For the reasons explained below, the Court AFFIRMS the Commissioner’s decision. I. JURISDICTION The Court has subject matter jurisdiction under 28 U.S.C. § 1331 because Plaintiff sues under 42 U.S.C. § 405(g). Venue is proper in the United States District Court, Northern

1 Due to concerns regarding the privacy of sensitive personal information available to the public through opinions in Social Security cases, Plaintiff is identified only by first name and last initial. District of Texas, Dallas Division because Plaintiff resides in Hunt County, Texas. 42 U.S.C. § 405(g). The undersigned has the authority to enter this Order and exercise the

full authority of this Court after the parties consented to the undersigned exercising jurisdiction. Special Order No. 3-350 (N.D. Tex. Sept. 11, 2023). II. FACTUAL BACKGROUND Plaintiff alleges a disability that began on October 9, 2020. Administrative Record, Dkt. No. 9 (Tr.) at 22. Plaintiff claims her disability is a product of variety of ailments, including, vestibular schwannoma, ulcerative colitis, obesity, psoriatic arthritis, poly

arthropathy, fibromyalgia, chronic fatigue, Ebola, liver disease, spine impairments, and mental impairments. Id. at 17. Plaintiff was born on April 3, 1977, and was forty-three years old on the alleged disability onset date. Id. at 215, 233. She has a general equivalency degree and attended some college classes. Id. at 103. Prior to the onset of her disability, Plaintiff worked as a

motel desk clerk and a merchandiser. Dkt. No. 12 at 6. On May 27, 2021, Plaintiff applied for a period of disability and disability insurance under Title II of the Social Security Act (Act). Tr. at 15. The Agency denied Plaintiff’s claims on March 24, 2022, and again upon reconsideration on December 6, 2022. Id. After holding a telephone hearing on June 26, 2023, an Administrative Law Judge (ALJ) issued

a decision denying Plaintiff disability benefits on September 7, 2023. Id. at 15-34. Plaintiff then requested the Appeals Council (AC) review that decision and submitted new medical evidence to support her claim. Id. at 1-7. The AC denied Plaintiff’s request for review, stating that the new evidence did not have a reasonable probability of changing the outcome of the case. Id. at 2.

III. PROCEDURAL HISTORY A. ALJ’s Decision The ALJ conducted a telephone hearing to review the denial of Plaintiff’s application and determine whether Plaintiff was disabled under the Act. Id. at 49-86. Shortly after this hearing, the ALJ found that Plaintiff was not disabled.2 Id. at 12-34. In doing so, the ALJ made the following findings (1) Plaintiff had not engaged in substantial

gainful activity since October 9, 2020, (2) Plaintiff had the following severe impairments: vestibular schwannoma, ulcerative colitis, obesity, psoriatic arthritis, and poly arthropathy, and (3) none of these impairments, alone or in combination, meets or medically equals the severity of one of the listed impairments in the Social Security Regulations. Id. at 17-22. In light of these impairments, the ALJ determined that Plaintiff had a residual

functioning capacity (RFC) to perform less than the full range of light work in that: [Lohmar] can lift and/or carry 20 pounds occasionally and 10 pounds frequently, stand and/or walk for 6 hours in an 8-hour workday, and sit for 6 hours in an 8-hour workday. However, she can never climb ladders, ropes, or scaffolds and can only occasionally balance, stoop, kneel, crouch, crawl, and climb ramps and stairs. Also, she must avoid vibration, hazards (such as dangerous moving machinery, unprotected heights, open flames, and bodies of water), and extremes of cold.

Id. at 22-23.

2 As discussed below, the Commissioner employs a five-step analysis to determine whether claimants are disabled under the Social Security Act. Based on this RFC, the ALJ then concluded that Plaintiff can perform her past work as a merchandiser. Id. at 29. Thus, the ALJ determined that Plaintiff had not been under a

disability from October 9, 2020. Id. B. Appeal Council’s Decision Plaintiff appealed the ALJ’s decision to the AC. Id. at 1-7. She submitted new medical evidence with this appeal including treatment records from Dr. Jeremiah Sisay and a medical source statement from Dr. Wasilla Amari. Id. The AC found that the new evidence did not show a reasonable probability that it would change the ALJ’s decision. Id.

It did not exhibit the evidence and it denied review. Id. Plaintiff subsequently filed this action in federal district court. B. Plaintiff’s Challenge Plaintiff challenges both the AC’s decision and the ALJ’s decision. Dkt. No. 12. With regards to the AC’s decision, she argues that the Council failed to properly justify its

denial because it did not directly address the persuasiveness of the new evidence she submitted on appeal. Id. at 19-21. The Plaintiff challenges the ALJ’s decision arguing that his RFC finding is not based on substantial evidence. Id. at 24-35. Specifically, Plaintiff argues that the ALJ erred when assessing her manipulative limitations, her mental impairments, and her ulcerative colitis. Id.

IV. LEGAL STANDARDS To be entitled to Social Security benefits, a claimant must show that they are disabled within the meaning of the Act. Leggett v. Chater, 67 F.3d 558, 563‒64 (5th Cir. 1995); Villa v. Sullivan, 895 F.2d 1019, 1022 (5th Cir. 1990). Disability is defined as the inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment that can be expected to last for a continuous

period of not less than twelve months. 42 U.S.C. § 423(d)(1)(A). Although a claimant bears the burden of establishing whether they meet the requirements for a disability, an ALJ’s finding that a claimant has not satisfied their burden must be based on substantial evidence. See, e.g., Belk v. Colvin, 648 F. App’x 452 (5th Cir. 2016) (per curiam). And judicial review of the Commissioner’s decision to deny benefits is limited to determining whether that decision is supported by substantial evidence and

whether the proper legal standards were applied to evaluate the evidence. See 42 U.S.C. § 405(g); Copeland v. Colvin, 771 F.3d 920, 923 (5th Cir. 2014); Ripley v. Chater, 67 F.3d 552, 555 (5th Cir. 1995). Substantial evidence means more than a scintilla, but less than a preponderance. Richardson v.

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Bluebook (online)
Lohmar v. Commissioner, Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lohmar-v-commissioner-social-security-administration-txnd-2024.