Rhodes v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedMarch 5, 2020
Docket6:18-cv-00329
StatusUnknown

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

Bluebook
Rhodes v. Social Security Administration, (E.D. Okla. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

AMANDA L. RHODES, ) ) Plaintiff, ) ) v. ) Case No. CIV-18-329-SPS ) COMMISSIONER of the Social ) Security Administration, ) ) Defendant. ) OPINION AND ORDER The claimant Amanda L. Rhodes requests judicial review of a denial of benefits by the Commissioner of the Social Security Administration pursuant to 42 U.S.C. § 405(g). She appeals the Commissioner’s decision and asserts that the Administrative Law Judge (“ALJ”) erred in determining she was not disabled. For the reasons set forth below, the Commissioner’s decision is hereby REVERSED and the case is REMANDED to the ALJ for further proceedings. Social Security Law and Standard of Review Disability under the Social Security Act is defined as the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment[.]” 42 U.S.C. § 423(d)(1)(A). A claimant is disabled under the Social Security Act “only if h[er] physical or mental impairment or impairments are of such severity that [s]he is not only unable to do h[er] previous work but cannot, considering h[er] age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy[.]” Id. § 423 (d)(2)(A). Social security regulations implement a five-step sequential process to evaluate a disability claim. See 20 C.F.R. §§ 404.1520, 416.920.1

Section 405(g) limits the scope of judicial review of the Commissioner’s decision to two inquiries: whether the decision was supported by substantial evidence and whether correct legal standards were applied. See Hawkins v. Chater, 113 F.3d 1162, 1164 (10th Cir. 1997). Substantial evidence is “‘more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’”

Richardson v. Perales, 402 U.S. 389, 401 (1971), quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938); see also Clifton v. Chater, 79 F.3d 1007, 1009 (10th Cir. 1996). The Court may not reweigh the evidence or substitute its discretion for the Commissioner’s. See Casias v. Secretary of Health & Human Services, 933 F.2d 799, 800 (10th Cir. 1991). But the Court must review the record as a whole, and “[t]he substantiality

of evidence must take into account whatever in the record fairly detracts from its weight.”

1 Step one requires the claimant to establish that she is not engaged in substantial gainful activity. Step two requires the claimant to establish that she has a medically severe impairment (or combination of impairments) that significantly limits her ability to do basic work activities. If the claimant is engaged in substantial gainful activity, or her impairment is not medically severe, disability benefits are denied. If she does have a medically severe impairment, it is measured at step three against the listed impairments in 20 C.F.R. Part 404, Subpt. P, App. 1. If the claimant has a listed (or “medically equivalent”) impairment, she is regarded as disabled and awarded benefits without further inquiry. Otherwise, the evaluation proceeds to step four, where the claimant must show that she lacks the residual functional capacity (“RFC”) to return to her past relevant work. At step five, the burden shifts to the Commissioner to show there is significant work in the national economy that the claimant can perform, given her age, education, work experience, and RFC. Disability benefits are denied if the claimant can return to any of her past relevant work or if her RFC does not preclude alternative work. See generally Williams v. Bowen, 844 F.2d 748, 750-51 (10th Cir. 1988). Universal Camera Corp. v. NLRB, 340 U.S. 474, 488 (1951); see also Casias, 933 F.2d at 800-01.

Claimant’s Background The claimant was thirty-six years old at the time of the administrative hearing (Tr. 33). Her education includes up to two years of college, and she has worked as a billing code clerk, a scheduling clerk, and a front desk clerk (Tr. 23, 216). The claimant alleges she has been unable to work since September 29, 2015, due to bipolar disorder, manic depressive disorder, severe social anxiety, PTSD, and anxiety (Tr. 215).

Procedural History The claimant applied for disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. §§ 401-434 on April 13, 2016, and for supplemental security income benefits under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381-85, on June 2, 2016. Her applications were denied. ALJ Ralph F. Shilling held an administrative

hearing and determined that the claimant was not disabled in a written opinion dated December 7, 2017 (Tr. 15-25). The Appeals Council denied review, so the ALJ’s written opinion is the Commissioner’s final decision for purposes of this appeal. See 20 C.F.R. §§ 404.981, 416.1481. Decision of the Administrative Law Judge

The ALJ made his decision at step five of the sequential evaluation. He found that the claimant had the residual functional capacity (“RFC”) to perform a full range of work at all exertional levels, but that she could not climb, use ladders, ropes, or scaffolds, and that she must avoid cold and heat extremes, wetness and humidity, as well as fumes, dusts, and odors. He further found that she had the ability to understand, remember, and carry out short and simple tasks and instructions, that work should be routine and repetitive, that

she could ask simple questions or request assistance, and that she could have occasional public contact as well as occasional supervisory and co-worker contact (Tr. 20). The ALJ then concluded that although the claimant could not return to her past relevant work, she was nevertheless not disabled because there was work she could perform, e. g., envelope addresser, lamp shade assembler, and eyeglass final assembler (Tr. 23-24).

Review The claimant contends that the ALJ erred by failing to properly evaluate the medical evidence related to her mental impairments, specifically with regard to the opinion of counselor Indira Fewell, MSW, and that the ALJ failed to properly evaluate her subjective complaints. The Court agrees that the ALJ failed to properly evaluate the evidence of record, and the decision of the Commissioner should therefore be reversed.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Hawkins v. Chater
113 F.3d 1162 (Tenth Circuit, 1997)
Watkins v. Barnhart
350 F.3d 1297 (Tenth Circuit, 2003)
Langley v. Barnhart
373 F.3d 1116 (Tenth Circuit, 2004)
Timmons v. Barnhart
118 F. App'x 349 (Tenth Circuit, 2004)
Haga v. Barnhart
482 F.3d 1205 (Tenth Circuit, 2007)
Frantz v. Astrue
509 F.3d 1299 (Tenth Circuit, 2007)
Hamby v. Astrue
260 F. App'x 108 (Tenth Circuit, 2008)
Andersen v. Astrue
319 F. App'x 712 (Tenth Circuit, 2009)
Miller v. Barnhart
43 F. App'x 200 (Tenth Circuit, 2002)
Vincent ex rel. Vincent v. Heckler
739 F.2d 1393 (Ninth Circuit, 1984)

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Rhodes v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rhodes-v-social-security-administration-oked-2020.