Niston v. Kijakazi

CourtDistrict Court, W.D. Texas
DecidedAugust 16, 2024
Docket5:23-cv-00862
StatusUnknown

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

Bluebook
Niston v. Kijakazi, (W.D. Tex. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

TIFFANY FOLEY NISTON, § § Plaintiff, § SA-23-CV-00862-OLG § vs. § § MARTIN O’MALLEY, ACTING § COMMISSIONER OF THE SOCIAL § SECURITY ADMINISTRATION, § § Defendant. §

REPORT AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE

To the Honorable United States District Judge Orlando L. Garcia: This report and recommendation concerns Plaintiff’s request for review of the administrative denial of her application for a period of disability and disability insurance benefits (“DIB”) under Title II of the Social Security Act. 42 U.S.C. §§ 405(g), 1383(c)(3). By this appeal Plaintiff argus the administrative law judge (“ALJ”) erred in finding she was capable of work at the light exertional level despite her pain symptoms and migraines and failed to properly evaluate her mental limitations in determining her capacity for work. The undersigned held a hearing on the issues raised in this appeal on May 13, 2024, at which counsel for both parties appeared. After considering Plaintiff’s Original Brief [#12], Defendant’s Brief in Support of the Commissioner’s Decision [#13], Plaintiff’s Reply Brief [#15], and the transcript (“Tr.”) of the administrative proceedings [#7], the applicable case authority and relevant statutory and regulatory provisions, the arguments of counsel at the hearing, and the entire record in this matter, the undersigned concludes that the Commissioner did not commit any reversible error in the underlying administrative proceedings and that substantial evidence supports the Commissioner’s decision denying disability benefits. It is therefore recommended that the Commissioner’s decision that Plaintiff is not disabled be affirmed. I. Jurisdiction

This Court has jurisdiction to review a decision of the Social Security Administration pursuant to 42 U.S.C. § 405(g). The undersigned has authority to enter this recommendation pursuant to 28 U.S.C. § 636(b)(1)(B). II. Legal Standard In reviewing the denial of benefits, the Court is limited to a determination of whether the Commissioner, through the ALJ’s decision,1 applied the proper legal standards and whether the Commissioner’s decision is supported by substantial evidence. Martinez v. Chater, 64 F.3d 172, 173 (5th Cir. 1995); 42 U.S.C. §§ 405(g), 1383(c)(3). “Substantial evidence is more than a scintilla, less than preponderance, and is such relevant evidence as a reasonable mind might

accept as adequate to support a conclusion.” Villa v. Sullivan, 895 F.2d 1019, 1021–22 (5th Cir. 1990) (quoting Hames v. Heckler, 707 F.2d 162, 164 (5th Cir. 1983)). The Court may not reweigh the evidence or substitute its judgment for that of the Commissioner. Newton v. Apfel, 209 F.3d 448, 452 (5th Cir. 2000). Conflicts in the evidence and credibility assessments are for the Commissioner, not the court, to resolve. Id. While substantial deference is afforded the Commissioner’s factual findings, the Commissioner’s legal conclusions, and claims of

1 In this case, because the Appeals Council declined to review the ALJ’s decision, the decision of the ALJ constitutes the final decision of the Commissioner, and the ALJ’s factual findings and legal conclusions are imputed to the Commissioner. See Higginbotham v. Barnhart, 405 F.3d 332, 336 (5th Cir. 2005); Harris v. Apfel, 209 F.3d 413, 414 (5th Cir. 2000). procedural error, are reviewed de novo. See Greenspan v. Shalala, 38 F.3d 232, 236 (5th Cir. 1994). In determining if a claimant is disabled, the Commissioner uses a sequential, five-step approach, which considers whether: (1) the claimant is currently engaged in substantial gainful activity, (2) she has a severe impairment, (3) the impairment meets the severity of an impairment

enumerated in the relevant regulations, (4) it prevents the claimant from performing past relevant work, and (5) it prevents her from doing any relevant work. Garcia v. Berryhill, 880 F.3d 700, 704 (5th Cir. 2018). If the claimant gets past the first four stages, then the burden shifts to the Commissioner on the fifth step to prove the claimant’s employability. Id. A finding that a claimant is not disabled at any point in the five-step review is conclusive and terminates the analysis. Lovelace v. Bowen, 813 F.2d 55, 58 (5th Cir. 1987); see also 20 C.F.R. § 404.1520(a)(4). III. Factual and Procedural Background Plaintiff Tiffany Foley Niston filed her application for DIB in January of 2021, alleging

disability beginning October 1, 2017. (Tr. 168.) At the time of her DIB application, Niston was 44 years old and had a GED and work experience as a file clerk, fast food manager, and truck driver. (Tr. 168, 196–97.) The medical conditions upon which Niston based her DIB application were chronic nerve pain, Tarvlov cysts in her spine, migraines, vertigo, disequilibrium, vision affected by migraines, depression, anxiety, morbid obesity, and cognitive decline. (Tr. 195.) The Social Security Administration (“SSA”) denied her application on November 5, 2021, and again upon reconsideration on May 4, 2022. (Tr. 66–86.) Following the denial of her claim, Niston requested an administrative hearing. Niston, her attorney, and a vocational expert attended the administrative hearing before ALJ Dwight Wilkerson on October 22, 2022. (Tr. 38–65.) At the hearing, Niston testified that she stopped working as a truck driver in 2017 due to migraines, vertigo, and back pain, which were causing difficulties sitting and with concentration, focus, and remembering simple tasks. (Tr. 43–44.) Additionally, Niston testified that her migraines—with their accompanying blurry vision and vertigo—make it impossible to drive. (Tr. 49.) At the ALJ’s hearing, Niston also described her difficulty sitting due to issues with her

legs and feet and the need to constantly switch positions to try to get comfortable due to back pain. (Tr. 46.) Niston testified that she can only stand for about ten minutes without experiencing excruciating back pain and also has difficulty holding objects more than ten pounds. (Tr. 46–47.) The ALJ issued an unfavorable decision on December 19, 2022. (Tr. 20–33.) The ALJ found that Niston met the insured-status requirements of the SSA and applied the five-step sequential analysis required by SSA regulations. At step one of the analysis, the ALJ found that Niston did not engage in substantial gainful activity between October 1, 2017, through the date of last insured. (Tr. 21.) At step two, the ALJ found Niston to have the severe impairments of

degenerative disc disease, obesity, migraines, and depression.

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Related

Acuna v. Brown & Root Inc.
200 F.3d 335 (Fifth Circuit, 2000)
Newton v. Apfel
209 F.3d 448 (Fifth Circuit, 2000)
Harris v. Apfel
209 F.3d 413 (Fifth Circuit, 2000)
Shave v. Apfel
238 F.3d 592 (Fifth Circuit, 2001)
Chambliss v. Massanari
269 F.3d 520 (Fifth Circuit, 2001)
Higginbotham v. Barnhart
405 F.3d 332 (Fifth Circuit, 2005)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)

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Niston v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/niston-v-kijakazi-txwd-2024.