Olsen v. King

CourtDistrict Court, D. Utah
DecidedJanuary 8, 2025
Docket1:22-cv-00173
StatusUnknown

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

Bluebook
Olsen v. King, (D. Utah 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF UTAH NORTHERN DIVISION

MARK O., REPORT AND RECOMMENDATION TO

AFFIRM THE COMMISSIONER’S Plaintiff, DECISION DENYING DISABILITY

BENEFITS v.

Case No. 1:22-cv-00173 CAROLYN W. COLVIN, Acting

Commissioner of the Social Security District Judge Dale A. Kimball Administration,

Magistrate Judge Daphne A. Oberg Defendant.

Mark O.1 brought this action for judicial review of the denial of his application for disability insurance benefits by the Commissioner of the Social Security Administration.2 The Administrative Law Judge (“ALJ”) who addressed Mr. O.’s application determined he did not qualify as disabled.3 Mr. O. asserts, without citation to record evidence, that the ALJ applied improper legal standards and his decision is unsupported by substantial evidence.4 In response, the Commissioner contends Mr. O.’s arguments are so undeveloped as to be waived.5 Because the record shows substantial evidence supports the ALJ’s findings regarding Mr. O.’s residual functional capacity, and all other

1 Pursuant to best practices in the District of Utah addressing privacy concerns in court orders in certain cases, including social security cases, the plaintiff is referred to by his first name and last initial only. 2 (See Compl., Doc. No. 2). 3 (Certified Tr. of Admin. R. (“Tr.”) 16–26, Doc. No. 18.) 4 (See Opening Br., Doc. No. 19 at 4–6.) 5 (See Answer Br. 3–4, Doc. No. 24.) arguments are waived, the undersigned6 recommends the district judge affirm the Commissioner’s decision. STANDARD OF REVIEW Section 405(g) of Title 42 of the United States Code provides for judicial review

of the Commissioner’s final decision. This court reviews the ALJ’s decision to determine whether substantial evidence supports his factual findings and whether he applied the correct legal standards.7 “[F]ailure to apply the correct legal standard or to provide this court with a sufficient basis to determine that appropriate legal principles have been followed is grounds for reversal.”8 An ALJ’s factual findings are “conclusive if supported by substantial evidence.”9 Although the evidentiary sufficiency threshold for substantial evidence is “not high,” it is “more than a mere scintilla.”10 Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”11 “The possibility of drawing two inconsistent conclusions from the evidence does not prevent an

6 This case is referred to the undersigned magistrate judge under 28 U.S.C. § 636(b)(1)(B). (Doc. No. 7.) 7 See 42 U.S.C. § 405(g); Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007). 8 Jensen v. Barnhart, 436 F.3d 1163, 1165 (10th Cir. 2005). 9 Biestek v. Berryhill, 587 U.S. 97, 102 (2019) (internal quotation marks omitted). 10 Id. at 103 (citation omitted). 11 Id. (citation omitted). administrative agency’s findings from being supported by substantial evidence.”12 And the court may not reweigh the evidence nor substitute its judgment for that of the ALJ.13 APPLICABLE LAW The Social Security Act defines “disability” as the inability “to engage in any

substantial gainful activity by reason of any medically determinable physical or mental impairment” which is expected to result in death or last for at least twelve consecutive months.14 An individual is considered disabled only if his impairments are so severe, he cannot perform his past work or “any other kind of substantial gainful work.”15 In determining whether a claimant qualifies as disabled, the ALJ uses a five-step sequential evaluation, considering whether: 1) the claimant is engaged in substantial gainful activity; 2) he has a severe medically determinable physical or mental impairment; 3) the impairment is equivalent to an impairment precluding substantial gainful activity (listed in the appendix of the relevant disability regulation);

4) he has the residual functional capacity to perform past relevant work; and 5) he has the residual functional capacity to perform other work, considering his age, education, and work experience.16

12 Lax, 489 F.3d at 1084 (citation omitted). 13 Langley v. Barnhart, 373 F.3d 1116, 1118 (10th Cir. 2004). 14 42 U.S.C. § 423(d)(1)(A). 15 Id. § 423(d)(2)(A). 16 See 20 C.F.R. § 404.1520(a)(4); Bowen v. Yuckert, 482 U.S. 137, 140–42 (1987); Williams v. Bowen, 844 F.2d 748, 750–51 (10th Cir. 1988). The claimant has the burden, in the first four steps, of establishing disability.17 At step five, the burden shifts to the Commissioner to show the claimant retains the ability to perform other work in the national economy.18 PROCEDURAL HISTORY

Mr. O. applied for disability insurance benefits under Title II of the Social Security Act19 in August 2019.20 He alleges he became disabled on April 4, 2019.21 After an administrative hearing, the ALJ issued a decision on March 9, 2022, finding Mr. O. not disabled.22 At step two of the sequential evaluation, the ALJ found Mr. O. had the following severe impairments: “general anxiety disorder (GAD), major depressive disorder (MDD), attention deficit hyperactivity disorder (ADHD) - inattentive type, post-traumatic stress disorder (PTSD), cervical degenerative disc disease (DDD), lumbar DDD, residuals from left second metacarpal partial amputation, and residuals from left shoulder arthroscopic surgery.”23 The ALJ also found Mr. O. had nonsevere impairments

17 Ray v. Bowen, 865 F.2d 222, 224 (10th Cir. 1989). 18 Id. 19 42 U.S.C. §§ 401–434. 20 (See Tr. 16.) 21 (See id.) 22 (Tr. 16–26.) 23 (Tr. 18.) including dermatitis and “residuals from COVID-19.”24 At step three, the ALJ found Mr. O.’s impairments did not meet or medically equal an impairment listing.25 The ALJ then found Mr. O. had the residual functional capacity to perform light work with the following limitations:

[N]o reaching overhead to the left (non-dominant), and no more than frequent reaching in all other directions with the left arm. He can do no more than frequent fingering or handling with the left hand (non-dominant). He can do no more than occasional crawling, can frequently climb ramps, stairs, and ladders, but not ropes or scaffolds. The claimant can never work at unprotected heights nor operate a motor vehicle. He is able to perform simple, routine and repetitive tasks. He is able to occasionally interact with supervisors and coworkers; he can work in proximity to others, but would work alone, not on a team. He is able to interact superficially with the public.26

At step four, the ALJ found Mr. O. unable to perform his past relevant work.27 But at step five, after considering the testimony of a vocational expert, the ALJ found Mr. O. could perform other work in the national economy.28 Therefore, the ALJ found Mr. O. not disabled and denied his claim.29 The Appeals Council denied Mr.

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