Marquez v. Social Security Administration

CourtDistrict Court, D. New Mexico
DecidedMarch 2, 2023
Docket1:21-cv-00451
StatusUnknown

This text of Marquez v. Social Security Administration (Marquez 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
Marquez v. Social Security Administration, (D.N.M. 2023).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW MEXICO

TINA LOUISE MARQUEZ,

Plaintiff,

v. Civ. No. 21-451 KWR/GJF

ANDREW M. SAUL, Commissioner of the Social Security Administration,

Defendant.

PROPOSED FINDINGS AND RECOMMENDED DISPOSITION THIS MATTER is before the Court on Plaintiff’s “Motion to Reverse and Remand with Supporting Memorandum” [ECF 24] (“Motion”). The Motion is fully briefed. See id.; ECFs 28 (“Resp.”), 35 (“Reply”). Having meticulously reviewed the entire record, and for the reasons articulated below, the Court RECOMMENDS1 the Motion be DENIED and this case DISMISSED WITH PREJUDICE. I. BACKGROUND Plaintiff is a 51-year-old unmarried mother of two grown sons and lives alone. See, e.g., Administrative Record (“AR”) at 54. She dropped out of school in the eighth grade but later obtained her general equivalency diploma (“GED”). AR at 318, 752. Prior to 2008, she worked as a telemarketer, leasing agent, accountant clerk, and subscription salesperson. AR at 47–48. Plaintiff’s disability claim traces back to 2008,2 when a major automobile collision allegedly left her with a traumatic brain injury (“TBI”), cognitive disorders, personality changes,

1 The Court files this Proposed Findings and Recommended Disposition (PFRD) pursuant to the presiding judge’s January 9, 2023, Order of Reference. ECF 40.

2 The record does not consistently establish whether all of Plaintiff’s mental conditions began with the 2008 accident. See AR at 318, 518 (Plaintiff’s own statement that her depression predated the accident); id. at 718 (warning Plaintiff that a prescription medication she began in 2017 “causes a type of clinical depression”). depression, and anxiety. AR at 22, 24, 49–50. She asserts that these conditions render her unable to work. AR at 49–50 (testifying that her short-term memory cripples her capacity to understand or remember simple instructions which invites criticism from her superiors that, in turn, compounds her depression and anxiety). Plaintiff also maintains that these conditions make her reluctant “to be around people” and that she experiences symptoms of agoraphobia. Mot. at 1; AR

at 20 (“I get really scared when people try to get in my space”), 23 (denying attending any events “for fun” or “get[ting] together with” friends). Despite these setbacks, Plaintiff managed to obtain her associate’s degree five years after the accident. AR at 16–17. After obtaining that degree, she found a job answering phones to the company’s apparent satisfaction. Id. at 753. She also held a series of short-lived jobs as a telemarketer, apartment leasing agent, some sort of “[d]ancer” in 2016, and occupied an unspecified role at Dillard’s in 2017. AR at 47–48, 491, 623. In September 2016, Plaintiff applied to the Social Security Administration (“SSA” or “Commissioner”) for disability insurance benefits and supplemental security income. The SSA approved her supplemental security income claim in June 2017 but denied her disability insurance

benefits claim. Id. at 1, 19, 71–85 (denying Plaintiff’s claim initially, on reconsideration, and by administrative law judge (“ALJ”) Ann Farris after a hearing; Appeals Council also declining to reverse the ALJ’s decision). The ALJ determined that Plaintiff could not perform any of her previous work, but she had the residual functional capacity (“RFC”) to perform other jobs existing nationwide in significant numbers. Id. at 28 (listing viable employment as a “[l]aboratory equipment cleaner,” “[h]ospital cleaner,” or “[w]all cleaner”). Thus, the ALJ found Plaintiff not disabled as defined by the Social Security Act. Id. at 19. Once the Appeals Council declined to revisit the ALJ’s decision, it became “final” agency action ripe for appeal to an Article III court. 20 C.F.R. § 404.984; accord 5 U.S.C. § 704.3 On May 13, 2021, Plaintiff sought review of the Commissioner’s decision in this Court. ECF 1.

II. STANDARD OF REVIEW A. Sequential Evaluation Process To qualify for disability benefits, a claimant must establish her 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 evaluate claims for benefits, the SSA uses a five-step sequential evaluation process. E.g., Barnhart v. Thomas, 540 U.S. 20, 24–25 (2003) (citing 20 C.F.R. § 416.920). The first four steps require the claimant to show that (1) “[s]he is not presently engaged in substantial gainful activity,” (2) “[s]he has a

medically severe impairment or combination of impairments,” and either (3) the impairment is equivalent to a listed impairment or (4) “the impairment or combination of impairments prevents h[er] from performing h[er] past work.” Williams v. Bowen, 844 F.2d 748, 750-51 (10th Cir. 1988); Grogan v. Barnhart, 399 F.3d 1257, 1261 (10th Cir. 2005). The claimant bears the burden of proof at steps one through four. See Bowen v. Yuckert, 482 U.S. 137, 146 & n.5 (1987); Grogan, 399 F.3d at 1261; Williams, 844 F.2d at 755–51, 751 n.2. If the claimant reaches step five, the burden of proof shifts to the Commissioner to show that the claimant retains sufficient capacity “to perform

3 “[W]hen a case is remanded by a Federal court for further consideration and the Appeals Council remands the case to an administrative law judge, . . . the decision of the administrative law judge . . . will become the final decision of the Commissioner after remand on your case unless the Appeals Council assumes jurisdiction of the case.” other work in the national economy in view of h[er] age, education, and work experience.” Yuckert, 482 U.S. at 142, 146 n.5. However, the claimant reassumes the burden once [s]he seeks judicial review. Id. at 146 (“An individual shall not be considered . . . disable[d] unless [s]he furnishes such medical and other evidence . . . as the [Commissioner] may require.”). B. Substantial Evidence

Judicial review of the ALJ’s five-step analysis and ultimate decision is both legal and factual. See, e.g., Maes v. Astrue, 522 F.3d 1093, 1096 (10th Cir. 2008) (internal citations omitted) (“The standard of review in a social security appeal is whether the correct legal standards were applied and whether the decision is supported by substantial evidence.”). If the ALJ applied the correct legal standards and supported h[er] findings with substantial evidence, the Commissioner’s decision stands. Langley v. Barnhart, 373 F.3d 1116, 1118 (10th Cir. 2004); Hamlin v. Barnhart, 365 F.3d 1208, 1214 (10th Cir. 2004). In determining whether the ALJ applied the correct legal standards, the Court evaluates whether [s]he “followed the specific rules of law” required for “weighing particular types of

evidence in disability cases.” Lax v.

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Bowen v. Yuckert
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United States v. Wooten
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Oldham v. Astrue
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Marquez v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marquez-v-social-security-administration-nmd-2023.