Parmer v. Commissioner, Social Security Administration

CourtDistrict Court, N.D. Texas
DecidedApril 28, 2025
Docket6:24-cv-00055
StatusUnknown

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

Bluebook
Parmer v. Commissioner, Social Security Administration, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS SAN ANGELO DIVISION

R.P.,1 § § Plaintiff, § § v. § 6:24-CV-55-BR § COMMISSIONER, § SOCIAL SECURITY ADMINISTRATION, § § § Defendant. §

MEMORANDUM OPINION AND ORDER VACATING AND REMANDING THE DECISION OF THE COMMISSION

Pursuant to 42 U.S.C. § 405(g), Plaintiff R.P. (“Plaintiff”) seeks judicial review of the decision of the Commissioner of Social Security (“Commissioner”), who denied Plaintiff’s application for a period of disability and disability insurance benefits under Title II of the Social Security Act (“SSA”) for lack of disability. (ECF 1; see also ECF 11-1 at 19). Before the Court is Plaintiff’s Opening Social Security Brief, (ECF 12), the Commissioner’s Response, (ECF 13), and Plaintiff’s Reply, (ECF 14). After considering the pleadings, briefs, and administrative record, the Court VACATES and REMANDS the Commissioner’s decision. I. PROCEDURAL BACKGROUND Plaintiff filed a claim for a period of disability and disability insurance benefits on July 7, 2022, alleging disability beginning October 5, 2018, due to osteoarthritis of the shoulders, hips, feet and

1 It is the undersigned’s practice to identify the plaintiff using only the first and last initial in filings in social security disability cases. This ensures that the public maintains access to the opinions (in compliance with Rule 5.2(c)(2)(B) of the Federal Rules of Civil Procedure and the E-Government Act of 2002) while still protecting the privacy of non- government parties’ identities within the opinion. knee, degenerative disc disease of the lumbar and cervical spine, obesity, diabetes mellitus, post- traumatic stress disorder, borderline personality disorder, and adjustment disorder. (ECF 11-1 at 24-25). Plaintiff was 46 years old on the date last insured and has at least a high school education. (ECF 11-1 at 29).

Plaintiff’s application was initially denied on May 3, 2023, and subsequently denied upon reconsideration on July 14, 2023. (ECF 11-1 at 22). After Plaintiff filed a written request for a hearing, the Administrative Law Judge (“ALJ”) held an online video hearing on January 10, 2024. (Id.) The ALJ issued an unfavorable opinion on April 17, 2024, denying Plaintiff’s claim, and finding that Plaintiff “was not under a disability within the meaning of the Social Security Act from October 5, 2018, through the date last insured.” (Id. at 23). The Appeals Council denied Plaintiff’s request for review on June 14, 2024. (Id. at 5). Therefore, the ALJ’s decision is the Commissioner’s final decision and is properly before the Court for review. See 42 U.S.C. §§ 405(g), 1383(c); Kneeland v. Berryhill, 850 F.3d 749, 755 (5th Cir. 2017) (“[C]ourts generally agree that when the Appeals Council denied a request for review, the

ALJ’s decision becomes the Commissioner’s final decision.”) (quoting Higginbotham v. Barnhart, 405 F.3d 332, 336 (5th Cir. 2005)). II. STANDARD OF REVIEW A person is disabled within the meaning of the Social Security Act if they are unable 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 twelve months.” 42 U.S.C. §§ 1382(c)(a)(3)(A), 423(d)(1)(A) (2012). “‘Substantial gainful activity’ is defined as a work activity involving significant physical or mental abilities for pay or profit.” Masterson v. Barnhart, 309 F.3d 267, 271 n.2 (5th Cir. 2002); 20 C.F.R. § 404.1572(a)–(b). When reviewing disability determinations made by the Commissioner, the court is “limited to two inquiries: whether substantial evidence supports the ALJ’s decision, and whether the ALJ

applied the proper legal standards when evaluating the evidence.” Taylor v. Astrue, 706 F.3d 600, 602 (5th Cir. 2012). Substantial evidence is defined as “such relevant evidence as a responsible mind might accept to support a conclusion. It is more than a mere scintilla and less than a preponderance.” Boyd v. Apfel, 239 F.3d 698, 704 (5th Cir. 2001). To determine whether substantial evidence of disability exists, the court must consider four elements of proof: (1) objective medical facts; (2) diagnoses and opinions of treating and examining physicians; (3) the claimant’s subjective evidence of pain and disability; and (4) the claimant’s age, education, and work history. Wren v. Sullivan, 925 F.2d 123, 126 (5th Cir. 1991) (citing DePaepe v. Richardson, 464 F.2d 92, 94 (5th Cir. 1972)). If the Commissioner’s findings are supported by substantial evidence, then the findings are conclusive. The reviewing court may

not substitute its own judgment for that of the Commissioner, even if the court determines the evidence preponderates toward a different finding. Strickland v. Harris, 615 F.2d 1103, 1106 (5th Cir. 1980). “The Court may not reweigh the evidence or substitute its judgment for that of the Commissioner.” Hernandez v. Comm'r of Soc. Sec., No. SA-23-CV-00633-ESC, 2024 WL 4126699, at *1 (W.D. Tex. Sept. 5, 2024). Conflicts in the evidence are resolved by the Commissioner, not the courts. Laffoon v. Califano, 558 F.2d 253, 254 (5th Cir. 1977). “Reversal is inappropriate if the agency's error was harmless—if it is inconceivable that a different administrative conclusion would have been reached even if the ALJ did not err.” Moreno v. Comm'r of Soc. Sec. Admin., 698 F. Supp. 3d 935, 939 (W.D. Tex. 2023) (cleaned up) (quoting Keel v. Saul, 986 F.3d 551, 556 (5th Cir. 2021). Only a “conspicuous absence of credible choices” or “no contrary medical evidence” will produce a finding of no substantial evidence. Hames v. Heckler, 707 F.2d 162, 164 (5th Cir. 1983). Stated differently, the level of review is not de novo. If the court finds substantial evidence to support the

Commissioner’s decision, the court must uphold the decision. See Selders v. Sullivan, 914 F.2d 614, 618 (5th Cir. 1990). III.

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Related

Boyd v. Apfel
239 F.3d 698 (Fifth Circuit, 2001)
Higginbotham v. Barnhart
405 F.3d 332 (Fifth Circuit, 2005)
Perez v. Barnhart
415 F.3d 457 (Fifth Circuit, 2005)
Audler v. Astrue
501 F.3d 446 (Fifth Circuit, 2007)
Uwe Taylor v. Michael Astrue, Commissioner
706 F.3d 600 (Fifth Circuit, 2012)
McNair v. Commissioner of Social Security Administration
537 F. Supp. 2d 823 (N.D. Texas, 2008)
Patsy Copeland v. Carolyn Colvin, Acting Cmsnr
771 F.3d 920 (Fifth Circuit, 2014)
Olivia Kneeland v. Nancy Berryhill, Acting Cmsnr
850 F.3d 749 (Fifth Circuit, 2017)
Keel v. Saul
986 F.3d 551 (Fifth Circuit, 2021)

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Parmer v. Commissioner, Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/parmer-v-commissioner-social-security-administration-txnd-2025.