Pope v. O'Malley

CourtDistrict Court, D. Utah
DecidedAugust 9, 2024
Docket2:23-cv-00890
StatusUnknown

This text of Pope v. O'Malley (Pope v. O'Malley) 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
Pope v. O'Malley, (D. Utah 2024).

Opinion

THE UNITED STATES DISTRICT COURT

DISTRICT OF UTAH

SARAH P., REPORT AND RECOMMENDATION

Plaintiff, Case No. 2:23-cv-00890-HCN-JCB v.

MARTIN J. O’MALLEY,1 Commissioner of Social Security, District Judge Howard C. Nielson, Jr.

Defendant. Magistrate Judge Jared C. Bennett

This case is referred to Magistrate Judge Jared C. Bennett under 28 U.S.C. § 636(b)(1)(B).2 Before the court is Plaintiff Sarah P.’s (“Plaintiff”) appeal of Commissioner of Social Security Martin J. O’Malley’s (“Commissioner”) final decision determining that Plaintiff was not entitled to Disability Insurance Benefits (“DIB”) under Title II of the Social Security Act.3 After careful consideration of the written briefs and the complete record, the court concludes that oral argument is not necessary. Based upon the analysis set forth below, the court recommends that the Commissioner’s decision be affirmed.

1 Martin J. O’Malley is now the Commissioner of Social Security. Under Fed. R. Civ. P. 25(d), he has been substituted for Acting Commissioner of Social Security Kilolo Kijakazi as the Defendant in this case. ECF No. 5. 2 ECF No. 4. 3 42 U.S.C. §§ 401-434. PROCEDURAL BACKGROUND Plaintiff alleges disability due to various physical and mental impairments. In November 2021, Plaintiff applied for DIB.4 Plaintiff’s application was denied initially5 and upon reconsideration.6 Plaintiff later appeared with counsel for a hearing before an Administrative Law Judge (“ALJ”),7 who issued a written decision denying Plaintiff’s claim for DIB.8 Plaintiff appealed the adverse ruling, and the Appeals Council denied her appeal,9 which made the ALJ’s decision final for purposes of judicial review.10 Thereafter, Plaintiff filed a complaint in this court seeking judicial review of the Commissioner’s final decision.11 STANDARD OF REVIEW This court “review[s] the Commissioner’s decision to determine whether the factual findings are supported by substantial evidence in the record and whether the correct legal standards were applied.”12 The Commissioner’s findings, “if supported by substantial evidence,

shall be conclusive.”13 “Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. It requires more than a scintilla, but less than a

4 ECF No. 11, Administrative Record (“AR ___”) 205-06. 5 AR 87-91. 6 AR 93-97. 7 AR 31-66. 8 AR 7-23. 9 AR 1-6. 10 42 U.S.C. § 405(g); 20 C.F.R. § 404.981. 11 ECF No. 1. 12 Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007) (quotations and citation omitted). 13 42 U.S.C. § 405(g). preponderance.”14 “In reviewing the ALJ’s decision, [this court may] neither reweigh the

evidence nor substitute [its] judgment for that of the [ALJ].”15 “The [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 [are] grounds for reversal.”16 The aforementioned standards apply to the Commissioner’s five-step evaluation process for determining whether a claimant is disabled.17 If a determination can be made at any one of the steps that a claimant is or is not disabled, the subsequent steps need not be analyzed.18 Step one determines whether the claimant is presently engaged in substantial gainful activity. If [the claimant] is, disability benefits are denied. If [the claimant] is not, the decision maker must proceed to step two: determining whether the claimant has a medically severe impairment or combination of impairments. . . . If the claimant is unable to show that [her] impairments would have more than a minimal effect on [her] ability to do basic work activities, [she] is not eligible for disability benefits. If, on the other hand, the claimant presents medical evidence and makes the de minimis showing of medical severity, the decision maker proceeds to step three.19

At step three, the claimant must show that his or her impairments meet or equal one of several listed impairments that are “severe enough to prevent an individual from doing any

14 Lax, 489 F.3d at 1084 (quotations and citation omitted). 15 Madrid v. Barnhart, 447 F.3d 788, 790 (10th Cir. 2006) (quotations and citation omitted). 16 Jensen v. Barnhart, 436 F.3d 1163, 1165 (10th Cir. 2005) (first alteration in original) (quotations and citation omitted). 17 20 C.F.R. § 404.1520(a)(4)(i)-(v); see also Williams v. Bowen, 844 F.2d 748, 750-51 (10th Cir. 1988) (discussing the five-step process). 18 20 C.F.R. § 404.1520(a)(4); see also Williams, 844 F.2d at 750. 19 Williams, 844 F.2d at 750-51 (quotations and citations omitted); see also 20 C.F.R. § 404.1520(a)(4)(i)-(ii). gainful activity, regardless of his or her age, education, or work experience.”20 “If the

impairment is listed and thus conclusively presumed to be disabling, the claimant is entitled to benefits. If not, the evaluation proceeds to the fourth step . . . .”21 Before considering step four, however, the ALJ must determine the claimant’s residual functional capacity (“RFC”).22 An individual’s RFC is her greatest ability to do physical and mental work activities on a regular and continuing basis despite limitations from her impairments.23 In making this determination, the ALJ must consider all of the claimant’s impairments, including impairments that are not severe.24 For the fourth step, the claimant must show, given her RFC, that her impairments prevent performance of her “past relevant work.”25 “If the claimant is able to perform [her] previous

work, [she] is not disabled.”26 If, however, the claimant is not able to perform her previous work, she “has met [her] burden of proof, establishing a prima facie case of disability.”27 From here, “[t]he evaluation process . . . proceeds to the fifth and final step,” where the burden of proof shifts to the Commissioner.28 The decision maker must determine “whether the claimant has the [RFC] to perform other work in the national economy in view of [her] age,

20 20 C.F.R. § 404.1525(a); see also id. § 404.1520(a)(4)(iii). 21 Williams, 844 F.2d at 751. 22 20 C.F.R. § 404.1520(a)(4), (e). 23 Id. § 404.1545(a)(1), (b)-(c). 24 Id. § 404.1545(a)(2). 25 Id. § 404.1520(a)(4)(iv). 26 Williams, 844 F.2d at 751. 27 Id. 28 Id. education, and work experience.”29 If it is determined that the claimant “can make an adjustment

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Pope v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pope-v-omalley-utd-2024.