Maez v. Social Security Administration

CourtDistrict Court, D. New Mexico
DecidedJune 9, 2025
Docket1:24-cv-00882
StatusUnknown

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

Bluebook
Maez v. Social Security Administration, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

JESSICA MAEZ,

Plaintiff,

vs. Civ. No. 24-882 JB/JFR

FRANK BISIGNANO, Commissioner, Social Security Administration,

Defendant.

PROPOSED FINDINGS AND RECOMMENDED DISPOSITION1

THIS MATTER is before the Court on the Social Security Administrative Record (Doc. 11)2 filed October 30, 2024, in connection with Plaintiff’s Opposed Motion to Reverse or Remand, filed January 24, 2025. Doc. 17. On April 10, 2025, Defendant filed a Response. Doc. 23. On April 18, 2025, Plaintiff filed a Reply. Doc. 24. The Court has jurisdiction to review the Commissioner’s final decision under 42 U.S.C. §§ 405(g) and 1383(c). Having meticulously reviewed the entire record and the applicable law and being fully advised in the premises, the Court finds that Plaintiff’s Motion is well-taken and recommends that it be GRANTED. I. Background and Procedural Record Plaintiff Jessica Maez (“Ms. Maez”) alleges that she became disabled on December 31, 2016, at the age of forty-three years and eight months, because of bipolar disorder, attention

1 On September 11, 2024, United States District Judge James O. Browning entered an Order of Reference referring this case to the undersigned to conduct hearings, if warranted, including evidentiary hearings and to perform any legal analysis required to recommend to the Court an ultimate disposition of the case. Doc. 9.

2 Hereinafter, the Court’s citations to Administrative Record (Doc. 11), which is before the Court as a transcript of the administrative proceedings, are designated as “Tr.” deficit/hyperactivity disorder, learning disability, anxiety, lack of concentration, and forgetfulness. Tr. 287. Ms. Maez completed high school having received special education throughout her schooling related to learning disabilities. Tr. 288. Ms. Maez has worked as a caregiver (family member), food preparer (public schools), and valet attendant (casino). Tr. 276. Ms. Maez stopped working on June 15, 2011, because of her alleged impairments. Tr. 287.

On December 20, 2021, Ms. Maez protectively filed applications for Social Security Disability Insurance Benefits (“DIB”) under Title II of the Social Security Act (the “Act”), 42 U.S.C. § 401 et seq., and for Supplemental Security Income (“SSI”) under Title XVI of the Act, 42 U.S.C. § 1381 et seq. Tr. 235-41, 242-48. On October 26, 2022, both applications were denied. Tr. 119, 120, 121-28, 129-36, 163-66. On June 30, 2023, Ms. Maez’s applications were denied at reconsideration. Tr. 137-45, 146, 147, 148-56, 170-72, 173-75. Ms. Maez requested a hearing before an Administrative Law Judge (“ALJ”), which was held on February 20, 2024. Tr. 96-118, 177. Ms. Maez appeared pro se.3 Id. On March 21, 2024, ALJ David Wurm issued an unfavorable decision. Tr. 96-118. On July 10, 2024, the Appeals Council issued its decision

denying Ms. Maez’s request for review and upholding the ALJ’s final decision. Tr. 18-23. On September 4, 2024, Ms. Maez timely filed a Complaint seeking judicial review of the Commissioner’s final decision. Doc. 1. Ms. Maez argues (1) that the Appeals Council should have considered the additional evidence she submitted during its review, i.e., Clifford O. Morgan, Ph.D.’s April 23, 2024, Psychological Evaluation Report and June 11, 2024, Medical Source Statement regarding Ms. Maez’s ability to do work-related mental activities; and (2) that the ALJ held that the opinions of state agency psychological consultants were persuasive and without explanation

3 Ms. Maez is represented in these proceedings by Attorney Benjamin Decker. Doc. 1. failed to include limitations pertaining to supervisors and work attendance in the RFC. Doc. 17 at 19-23. For the reasons discussed below, the Court finds the Appeals Council failed to consider the additional evidence Ms. Maez submitted during its review. The Court, therefore, recommends that this matter be remanded for review of the additional evidence as required under 20 C.F.R. §§ 404.970(a)(5), 416.1470(a)(5).

II. Applicable Law A. Disability Determination Process An individual is considered disabled if she is unable “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) (pertaining to disability insurance benefits); see also 42 U.S.C. § 1382(a)(3)(A) (pertaining to supplemental security income disability benefits for adult individuals). The Social Security Commissioner has adopted the familiar five-step sequential analysis to determine whether a person satisfies the statutory criteria

as follows: (1) At step one, the ALJ must determine whether the claimant is engaged in “substantial gainful activity.”4 If the claimant is engaged in substantial gainful activity, she is not disabled regardless of her medical condition.

(2) At step two, the ALJ must determine the severity of the claimed physical or mental impairment(s). If the claimant does not have an impairment(s) or combination of impairments that is severe and meets the duration requirement, she is not disabled.

(3) At step three, the ALJ must determine whether a claimant’s impairment(s) meets or equals in severity one of the listings described in Appendix 1 of the

4 Substantial work activity is work activity that involves doing significant physical or mental activities. 20 C.F.R. §§ 404.1572(a). “Your work may be substantial even if it is done on a part-time basis or if you do less, get paid less, or have less responsibility than when you worked before.” Id. “Gainful work activity is work activity that you do for pay or profit.” 20 C.F.R. §§ 404.1572(b). regulations and meets the duration requirement. If so, a claimant is presumed disabled.

(4) If, however, the claimant’s impairments do not meet or equal in severity one of the listings described in Appendix 1 of the regulations, the ALJ must determine at step four whether the claimant can perform her “past relevant work.” Answering this question involves three phases. Winfrey v. Chater, 92 F.3d 1017, 1023 (10th Cir. 1996). First, the ALJ considers all of the relevant medical and other evidence and determines what is “the most [claimant] can still do despite [her physical and mental] limitations.” 20 C.F.R. § 404.1545(a)(1). This is called the claimant’s residual functional capacity (“RFC”). Id. §§ 404.1545(a)(3). Second, the ALJ determines the physical and mental demands of claimant’s past work. Third, the ALJ determines whether, given claimant’s RFC, the claimant is capable of meeting those demands.

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