Rater v. Commissioner, Social Security Administration

CourtDistrict Court, N.D. Texas
DecidedMay 2, 2025
Docket7:24-cv-00142
StatusUnknown

This text of Rater v. Commissioner, Social Security Administration (Rater 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
Rater v. Commissioner, Social Security Administration, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS WICHITA FALLS DIVISION

LESLIE RATER, § § Plaintiff, § § v. § Civil Action No. 7:24-cv-0142-BP § COMMISSIONER, SOCIAL § SECURITY ADMINISTRATION, § § Defendant. §

MEMORANDUM OPINION AND ORDER Leslie Rater (“Rater”) applied for Title II Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”) under the Social Security Act (“SSA”). The Commissioner denied her application, deciding that she was not disabled. Rater appealed, but the Social Security Appeals Council (“AC”) rejected her request for review. There is no reversible error in the legal standard that the Administrative Law Judge (“ALJ”) applied, and substantial evidence supports her determination that Rater was not disabled. Accordingly, the Court AFFIRMS the Commissioner’s decision and DISMISSES the case with prejudice. I. BACKGROUND Rater applied for DIB and SSI on August 30, 2021. Soc. Sec. Admin. R. (“Tr.”) ECF No. 7-1 at 23. She alleged disability beginning on September 15, 2020. Id. The Commissioner denied her application initially on July 6, 2022, and upon reconsideration on May 1, 2023. Tr. 18. Rater challenged the Commissioner’s denial in a hearing before an ALJ, who affirmed the Commissioner’s decision on June 6, 2024. Id. at 15-35. Rater appealed the decision to the AC, which denied review on September 11, 2024. Id. at 1-3. “[T]he Commissioner’s decision does not become final until after the [AC] makes its decision denying the claimant’s request for review.” Higginbotham v. Barnhart, 405 F.3d 332, 337 (5th Cir. 2005). Rater then filed this civil action seeking judicial review of the Commissioner’s decision under 42 U.S.C. §§ 405(g), 1383(c)(3). ECF No. 1. II. STANDARD OF REVIEW Titles II and XVI of the SSA govern the DIB program and SSI programs, respectively. See

42 U.S.C. §§ 401-434; §§1381-1383f. Claimants seeking benefits under either program must prove that they are “disabled” within the meaning of the SSA. See Hollis v. Bowen, 837 F.2d 1378, 1382 n.3 (5th Cir. 1988) (stating the “relevant law and regulations governing the determination of disability under a claim for [DIB] are identical to those governing the determination under a claim for [SSI]”). A person is disabled if he is unable “to engage in any substantial gainful activity (“SGA”) 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 12 months.” 42 U.S.C. § 423(d)(1)(A), § 1382c(a)(3)(A). To determine whether a claimant is disabled and thus entitled to benefits, the Commissioner employs a sequential five-step

evaluation process. 20 C.F.R. §§ 404.1520(a), 416.920(a). First, the claimant must not be presently doing any SGA. Id. § 404.1520(a)(4)(i). SGA is work that “involves doing significant physical or mental activities” for pay or profit. Id. § 404.1572. Second, the claimant must have a severe impairment or combination of impairments. Id. § 404.1520(a)(4)(ii). Third, disability exists if the impairment or combination of impairments meets or equals an impairment in the federal regulatory list. See 20 C.F.R. § 404.1520(a)(4)(iii) (referencing 20 C.F.R. pt. 404, subpt. P, app. 1). Before proceeding to steps four and five, the Commissioner assesses the claimant’s RFC and considers her past relevant work (“PRW”). See id. § 404.1520(a)(4), (e)-(f). RFC means “the most [a claimant] can still do despite [her] limitations.” Id. § 404.1545(a)(1). Previously, PRW meant work the claimant performed “within the past 15 years, that was SGA, and that lasted long enough for [the claimant] to learn to do it.” Id. § 404.1560(b)(1). The definition has since changed, and as of June 22, 2024, PRW means the “work that you have done

within the past five years that was SGA and that lasted long enough for you to learn to do it.” 20 C.F.R. § 404.1560(b)(2). The Commissioner made the decision regarding Rater’s application prior to June 22, 2024, so the previous definition is proper in this case. See Tr. 15. Fourth, if the claimant’s medical status alone does not constitute a disability, the impairment or impairments must prevent the claimant from returning to her PRW considering his or her RFC. Id. § 404.1520(a)(4)(iv). Fifth, the impairment must prevent the claimant from doing any other relevant work, considering the claimant’s RFC, age, work experience, and education. Id. § 404.1520(a)(4)(v); Crowley v. Apfel, 197 F.3d 194, 197-98 (5th Cir. 1999). “A finding that a claimant is disabled or 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). “The claimant bears the burden of showing [she] is disabled through the first four steps of the analysis; on the fifth, the Commissioner must show that there is other substantial work in the national economy that the claimant can perform.” Audler v. Astrue, 501 F.3d 446, 448 (5th Cir. 2007). Judicial review is limited to determining whether the Commissioner applied correct legal standards and whether substantial evidence in the record supports the Commissioner’s decision. Leggett v. Chater, 67 F.3d 558, 564 (5th Cir. 1995); Hollis, 837 F.2d at 1382. “Substantial evidence is such relevant evidence as a reasonable mind might accept to support a conclusion.” Ripley v. Chater, 67 F.3d 552, 555 (5th Cir. 1995) (quoting Greenspan v. Shalala, 38 F.3d 232, 236 (5th Cir. 1994)). “It is more than a mere scintilla and less than a preponderance.” Boyd v. Apfel, 239 F.3d 698, 704 (5th Cir. 2001) (quoting Harris v. Apfel, 209 F.3d 413, 417 (5th Cir. 2000)). “A finding of no substantial evidence is appropriate only if no credible evidentiary choices or medical findings support the decision.” Id. (quoting same). The Court may neither reweigh evidence in the

record nor substitute its judgment for the Commissioner’s, but it will carefully scrutinize the record to determine if substantial evidence is present. Harris, 209 F.3d at 417; Hollis, 837 F.2d at 1383. “Conflicts in the evidence are for the [Commissioner] and not the courts to resolve.” Brown v. Apfel, 192 F.3d 492, 496 (5th Cir. 1999) (alteration in original) (quoting Selders v.

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Related

Brown v. Apfel
192 F.3d 492 (Fifth Circuit, 1999)
Crowley v. Apfel
197 F.3d 194 (Fifth Circuit, 1999)
Harris v. Apfel
209 F.3d 413 (Fifth Circuit, 2000)
Myers v. Apfel
238 F.3d 617 (Fifth Circuit, 2001)
Boyd v. Apfel
239 F.3d 698 (Fifth Circuit, 2001)
Higginbotham v. Barnhart
405 F.3d 332 (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)
James Barrett v. Nancy Berryhill, Acting Cmsnr
906 F.3d 340 (Fifth Circuit, 2018)
Webster v. Kijakazi
19 F.4th 715 (Fifth Circuit, 2021)

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