McCoy v. O'Malley

CourtDistrict Court, S.D. Texas
DecidedMay 16, 2025
Docket3:24-cv-00301
StatusUnknown

This text of McCoy v. O'Malley (McCoy v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, S.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
McCoy v. O'Malley, (S.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT May 16, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk GALVESTON DIVISION T.M., § § Plaintiff. § § V. § CIVIL ACTION NO. 3:24-cv-00301 § COMMISSIONER OF SOCIAL § SECURITY, § § Defendant. §

OPINION AND ORDER Plaintiff T.M. seeks judicial review of an administrative decision denying her application for disability and disability insurance benefits under Title II of the Social Security Act (the “Act”). T.M. and Defendant Frank Bisignano, the Commissioner of the Social Security Administration (the “Commissioner”)1 have both filed briefs. See Dkts. 14, 17. After reviewing the briefing, the record, and the applicable law, I reverse the Commissioner’s decision and remand this case to the Commissioner for further proceedings consistent with this Opinion. BACKGROUND On May 4, 2021, T.M. filed a Title II application for disability and disability insurance benefits alleging disability beginning March 14, 2020. Her application was denied and denied again upon reconsideration. Subsequently, an Administrative Law Judge (“ALJ”) held a hearing and found that T.M. was not disabled. T.M. filed an appeal with the Appeals Council. The Appeals Council denied review, making the ALJ’s decision final and ripe for judicial review.

1 Frank Bisignano became the Commissioner of Social Security on May 6, 2025. Bisignano is “automatically substituted” as the defendant in this suit. Fed. R. Civ. P. 25(d); see also 42 U.S.C. § 405(g) (“Any action instituted in accordance with this subsection shall survive notwithstanding any change in the person occupying the office of Commissioner of Social Security or any vacancy in such office.”). APPLICABLE LAW The standard of judicial review for disability appeals is provided in 42 U.S.C. § 405(g). See Waters v. Barnhart, 276 F.3d 716, 718 (5th Cir. 2002). Courts reviewing the Commissioner’s denial of social security disability applications limit their analysis to “(1) whether the Commissioner applied the proper legal standards; and (2) whether the Commissioner’s decision is supported by substantial evidence on the record as a whole.” Est. of Morris v. Shalala, 207 F.3d 744, 745 (5th Cir. 2000). Addressing the evidentiary standard, the Fifth Circuit has explained: Substantial evidence is that which is relevant and sufficient for a reasonable mind to accept as adequate to support a conclusion; it must be more than a scintilla, but it need not be a preponderance. It is the role of the Commissioner, and not the courts, to resolve conflicts in the evidence. As a result, [a] court cannot reweigh the evidence, but may only scrutinize the record to determine whether it contains substantial evidence to support the Commissioner’s decision. A finding of no substantial evidence is warranted only where there is a conspicuous absence of credible choices or no contrary medical evidence. Ramirez v. Colvin, 606 F. App’x 775, 777 (5th Cir. 2015) (cleaned up). Judicial review is limited to the reasons relied on as stated in the ALJ’s decision, and post hoc rationalizations are not to be considered. See SEC v. Chenery Corp., 332 U.S. 194, 196 (1947). Under the Act, “a claimant is disabled only if she is incapable of engaging in any substantial gainful activity.” Anthony v. Sullivan, 954 F.2d 289, 293 (5th Cir. 1992) (quotation omitted). The Commissioner uses a five-step approach to determine if a claimant is disabled, including: (1) whether the claimant is presently performing substantial gainful activity; (2) whether the claimant has a severe impairment; (3) whether the impairment meets or equals a listed impairment; (4) whether the impairment prevents the claimant from doing past relevant work; and (5) whether the impairment prevents the claimant from performing any other substantial gainful activity. Salmond v. Berryhill, 892 F.3d 812, 817 (5th Cir. 2018) (quoting Kneeland v. Berryhill, 850 F.3d 749, 753 (5th Cir. 2017)). The burden of proof lies with the claimant during the first four steps before shifting to the Commissioner at Step 5. See Salmond, 892 F.3d at 817. Between Steps 3 and 4, the ALJ considers the claimant’s residual functional capacity (“RFC”), which serves as an indicator of the claimant’s maximum capabilities given the physical and mental limitations detailed in the administrative record. See Kneeland, 850 F.3d at 754. The RFC also helps the ALJ “determine whether the claimant is able to do her past work or other available work.” Id. THE ALJ’S DECISION The ALJ found at Step 1 that T.M. “did not engage in substantial gainful activity during the period from her alleged onset date of March 14, 2020, through her date last insured of December 31, 2023.” Dkt. 9-3 at 17. The ALJ found at Step 2 that T.M. “had the following severe impairments: degenerative disc disease; osteoarthritis of the hands; obesity; Chron’s disease, irritable bowel syndrome, and GERD; hiatal hernia; endometriosis of the colon; fibromyalgia; migraine headaches; adjustment disorder with mixed anxiety and depressed mood/depressive disorder.” Id. At Step 3, the ALJ found that T.M. “did not have an impairment or combination of impairments that met or medically equaled the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1.” Id. at 19. Prior to consideration of Step 4, the ALJ determined T.M.’s RFC as follows: Through the date last insured, [T.M.] had the residual functional capacity to perform light work between as defined in 20 CFR 404.1567(b), except that [T.M.] could have engaged in no more than frequent handling and fingering. [T.M.] could have been exposed to no more than a moderate level of noise. [T.M.] could have understood, remembered, and carried out detailed non-complex tasks involving detailed non-complex instructions, and she could have no more than occasional workplace changes. Id. at 24. At Step 4, the ALJ found that T.M. “was unable to perform her past relevant work.” Id. at 29. At Step 5, the ALJ elicited testimony from a vocational expert (“VE”) that “[t]hrough the date last insured, . . . there were jobs that existed in significant numbers in the national economy that [T.M.] could have performed.” Id. at 30. Accordingly, the ALJ found that T.M. “was not under a disability, as defined in the Social Security Act, at any time from March 14, 2020, the alleged onset date, through December 31, 2023, the date last insured.” Id. at 31. DISCUSSION T.M. raises three issues for my review. First, T.M. argues that the ALJ’s RFC is not supported by substantial evidence. Second, T.M. argues that the ALJ erred at Step 3 when he found that T.M.’s migraines do not medically equal Listing 11.02 for epilepsy. Finally, T.M. argues that the ALJ erred by failing to properly evaluate her fibromyalgia under Social Security Rule 12-2p. I need reach only the first of these issues.

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Related

Estate of Morris v. Shalala
207 F.3d 744 (Fifth Circuit, 2000)
Waters v. Barnhart
276 F.3d 716 (Fifth Circuit, 2002)
Williams v. Astrue
355 F. App'x 828 (Fifth Circuit, 2009)
Securities & Exchange Commission v. Chenery Corp.
332 U.S. 194 (Supreme Court, 1947)
Linda Ramirez v. Carolyn Colvin, Acting Cmsnr
606 F. App'x 775 (Fifth Circuit, 2015)
Olivia Kneeland v. Nancy Berryhill, Acting Cmsnr
850 F.3d 749 (Fifth Circuit, 2017)
Ronald Salmond, Sr. v. Nancy Berryhill, Acting Cms
892 F.3d 812 (Fifth Circuit, 2018)

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Bluebook (online)
McCoy v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mccoy-v-omalley-txsd-2025.