McAfee v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedSeptember 28, 2020
Docket6:19-cv-00216
StatusUnknown

This text of McAfee v. Social Security Administration (McAfee 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
McAfee v. Social Security Administration, (E.D. Okla. 2020).

Opinion

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

ROGER D. MCAFEE, ) ) Plaintiff, ) ) v. ) Case No. CIV-19-216-KEW ) COMMISSIONER OF SOCIAL ) SECURITY ADMINISTRATION, ) ) Defendant. )

OPINION AND ORDER

Plaintiff Roger D. McAfee (the “Claimant”) requests judicial review of the decision of the Commissioner of the Social Security Administration (the “Commissioner”) denying Claimant’s application for disability benefits under the Social Security Act. Claimant appeals the decision of the Administrative Law Judge (“ALJ”) and asserts that the Commissioner erred because the ALJ incorrectly determined that Claimant was not disabled. For the reasons discussed below, it is the finding of this Court that the Commissioner’s decision should be and is AFFIRMED. Social Security Law and Standard of Review Disability under the Social Security Act is defined as the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment. . .” 42 U.S.C. § 423(d)(1)(A). A claimant is disabled under the Social Security Act “only if his physical or mental impairment or impairments are 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). Social Security regulations implement a five-step sequential process to evaluate a disability claim. See, 20 C.F.R. §§ 404.1520, 416.920.1 Judicial review of the Commissioner’s determination is

1 Step one requires the claimant to establish that he is not engaged in substantial gainful activity, as defined by 20 C.F.R. §§ 404.1510, 416.910. Step two requires that the claimant establish that he has a medically severe impairment or combination of impairments that significantly limit his ability to do basic work activities. 20 C.F.R. §§ 404.1521, 416.921. If the claimant is engaged in substantial gainful activity (step one) or if the claimant’s impairment is not medically severe (step two), disability benefits are denied. At step three, the claimant’s impairment is compared with certain impairments listed in 20 C.F.R. Pt. 404, Subpt. P, App. 1. A claimant suffering from a listed impairment or impairments “medically equivalent” to a listed impairment is determined to be disabled without further inquiry. If not, the evaluation proceeds to step four, where claimant must establish that he does not retain the residual functional capacity (“RFC”) to perform his past relevant work. If the claimant’s step four burden is met, the burden shifts to the Commissioner to establish at step five that work exists in significant numbers in the national economy which the claimant – taking into account his age, education, work experience, and RFC – can perform. Disability benefits are denied if the Commissioner shows that the impairment which precluded the performance of past relevant work does not preclude alternative work. See generally, Williams v. Bowen, 844 F.2d 748, 750-51 (10th Cir. 1988).

2 limited in scope by 42 U.S.C. § 405(g). This Court’s review is limited to two inquiries: first, whether the decision was supported by substantial evidence; and, second, whether the

correct legal standards were applied. Hawkins v. Chater, 113 F.3d 1162, 1164 (10th Cir. 1997)(citation omitted). The term “substantial evidence” has been interpreted by the United States Supreme Court to require “more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402

U.S. 389, 401 (1971) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). The court may not re-weigh the evidence nor substitute its discretion for that of the agency. Casias v. Secretary of Health & Human Servs., 933 F.2d 799, 800 (10th Cir. 1991). Nevertheless, the court must review the record as a whole,

and the “substantiality of the evidence must take into account whatever in the record fairly detracts from its weight.” Universal Camera Corp. v. NLRB, 340 U.S. 474, 488 (1951); see also, Casias, 933 F.2d at 800-01. Claimant’s Background Claimant was 55 years old at the time of the ALJ’s decision.

Claimant completed his high school education. Claimant has worked

3 in the past as a truck driver. Claimant alleges an inability to work beginning July 1, 2016 due to limitations resulting from vision problems, hypertension, depression, hypolipidemia, and

obesity. Procedural History On January 26, 2017, Claimant protectively filed for disability insurance benefits under Title II (42 U.S.C. ' 401, et seq.) of the Social Security Act. Claimant’s application was

denied initially and upon reconsideration. On November 5, 2018, Administrative Law Judge (“ALJ”) David Engel conducted a hearing in Fort Smith, Arkansas. On December 7, 2018, the ALJ entered an unfavorable decision. On June 24, 2019, the Appeals Council denied review. As a result, the decision of the ALJ represents the Commissioner’s final decision for purposes of further appeal.

20 C.F.R. §§ 404.981, 416.1481. Decision of the Administrative Law Judge The ALJ made his decision at step five of the sequential evaluation. He determined that while Claimant suffered from severe impairments, he retained the residual functional capacity

(“RFC”) to perform medium work with limitations. Error Alleged for Review

4 Claimant asserts the ALJ committed error in (1) reaching an improper RFC determination; and (2) failing to adequately consider all of Claimant’s limitations at step five.

RFC Determination In his decision, the ALJ determined Claimant suffered from the severe impairments of age-related macular degeneration and hypertension. (Tr. 17). The ALJ concluded Claimant could perform medium work. In so doing, the ALJ found Claimant could lift, carry, push, or pull up at a medium exertional level but he was

unable to work in environments where he would be exposed to unprotected heights and dangerous moving machinery parts. Claimant was also found by the ALJ to be unable to perform tasks requiring visual acuity (defined as a distance of 20 feet or more – e.g., eyesight needed to operate a forklift or other motorized

equipment) more than occasionally and was unable to perform tasks requiring night vision more than occasionally. The ALJ stated Claimant could understand, remember, and carry out simple to moderately detailed instructions and was able to interact with co- workers and supervisors under routine supervision.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Hawkins v. Chater
113 F.3d 1162 (Tenth Circuit, 1997)
Bainbridge v. Colvin
618 F. App'x 384 (Tenth Circuit, 2015)
Madrid v. Astrue
243 F. App'x 387 (Tenth Circuit, 2007)
Higgs v. Bowen
880 F.2d 860 (Sixth Circuit, 1988)

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McAfee v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcafee-v-social-security-administration-oked-2020.