Richard v. Social Security Administration

CourtDistrict Court, E.D. Louisiana
DecidedMay 22, 2025
Docket2:24-cv-01701
StatusUnknown

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

Bluebook
Richard v. Social Security Administration, (E.D. La. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF LOUISIANA

CRYSTAL RICHARD, CIVIL ACTION Plaintiff

VERSUS NO. 24-1701

SOCIAL SECURITY ADMINISTRATION, SECTION: “E” Defendant

ORDER AND REASONS Before the Court is a Report and Recommendation issued by Magistrate Judge Michael North.1 On November 3, 2024, Plaintiff Crystal Richard (“Plaintiff”) filed a Brief in Support of Summary Judgment.2 On January 16, 2025, the Acting Commissioner of the Social Security Administration (the “Commissioner”) filed a brief in opposition.3 On January 30, 2025, Plaintiff filed a reply brief.4 BACKGROUND Plaintiff seeks judicial review, pursuant to Section 405(g) of the Social Security Act (the “Act”), of the final decision of the Commissioner of the Social Security Administration (the “Commissioner”) denying her claim for disability insurance benefits (“DIB”) under Title II of the Act and Supplemental Security Income (“SSI”) under Title XVI of the Act.5 Plaintiff is a 44-year-old woman with past work experience as an assistant manager and team leader at a fast-food restaurant, a cashier at a casino, a customer service

1 R. Doc. 14. This Order refers to documents on this Court’s CM/ECF docket as “R. Doc. [#]” and refers to the administrative record as “Tr.” The administrative record is located on the CM/ECF docket as Documents 6, 6-1, 6-2, and 6-3. 2 R. Doc. 9. 3 R. Doc. 12. 4 R. Doc. 13. 5 R. Doc. 1. manager at Walmart, and a worker at a rice mill.6 On December 11, 2023, she filed an application for DIB and SSI alleging disability that began on November 14, 2016.7 Plaintiff alleges she suffered from bipolar disorder, depression, panic disorder with agoraphobia, diabetes type 2, non-alcoholic fatty liver disease, and high blood pressure.8 The agency denied Plaintiff’s DIB and SSI applications on March 22, 2022,9 and

denied the applications again upon reconsideration on October 13, 2022.10 Plaintiff submitted her written request for hearing on February 1, 2022,11 after which Administrative Law Judge (“ALJ”) Michael Hertzig held a hearing on August 22, 2023.12 Plaintiff, represented by counsel, testified at the hearing.13 A vocational expert also testified.14 On November 2, 2023, the ALJ denied Plaintiff’s applications for benefits.15 In relevant part, “[a]fter careful consideration of the entire record,”16 the ALJ found “the claimant’s physical and mental impairments, considered singly and in combination, do not significantly limit the claimant’s ability to perform basic work activities. Thus, the claimant does not have a severe impairment or combination of impairments.17

6 Tr. at pp. 166, 193-94. 7 Id. at pp. 166-69, 173-177. 8 Id. at p. 192. 9 Id. at pp. 72-75. 10 Id. at pp. 84-85. 11 Id. at p. 70. 12 Id. at pp. 29-55. 13 Id. 14 Id. 15 Id. at pp. 12-24. 16 Id. at p. 21. 17 Id. at p. 23. Plaintiff sought Appeals Council review, and the Appeals Council denied her request for review on May 3, 2024.18 That denial rendered the ALJ’s decision the final decision of the Commissioner for purposes of this Court’s review.19 Plaintiff then filed this action for review of the Commissioner’s decision under the Act on July 6, 2024,20 and the Commissioner answered on September 4, 2024.21

“Pursuant to Rule 5 of the Supplemental Rules for Social Security Actions Under 42 U.S.C. § 405(g) . . . , an action for review of a final decision of the Commissioner is initiated with a complaint and ‘presented for decision by the parties’ briefs.’”22 The briefing “may, but need not, take the form of motions for summary judgment.”23 No matter the styling of the briefing, “the Court must determine whether to render judgment in favor of plaintiff and reverse or remand the case to the SSA, or dismiss plaintiff’s complaint and affirm the Commissioner’s decision under” the Act.24 Plaintiff filed her “Brief in Support of Summary Judgment” on November 3, 2024,25 the Commissioner filed a response in opposition on January 16, 2025,26 and Plaintiff filed a reply on January 30, 2025.27 The pleadings were referred to the magistrate judge, who issued his Report and Recommendation on April 3, 2025, recommending that

Plaintiff’s Brief be rejected and her complaint be dismissed with prejudice.28 Plaintiff filed an objection to the Report and Recommendation on April 17, 2025.29

18 Id. at pp. 1-3. 19 Id. 20 R. Doc. 1. 21 R. Doc. 5. 22 Muhleisen v. Soc. Sec. Admin., No. 23-1064, 2024 WL 139525, at *2 (E.D. La. Jan. 12, 2024). 23 Id. (citing Higginbotham v. Barnhart, 163 Fed. App’x 279, 281 (5th Cir. 2006)). 24 Id. (citing Rule 5 of the Supplemental Rules for Social Security Actions Under 42 U.S.C. § 405(g)). 25 R. Doc. 9. 26 R. Doc. 12. 27 R. Doc. 13. 28 R. Doc. 14. 29 R. Doc. 15. LEGAL STANDARD In reviewing the magistrate judge’s Report and Recommendation, the Court must review de novo any of the magistrate judge’s conclusions to which a party has specifically objected.30 The Court needs only to review the portions of the report to which there are no objections to determine whether they are clearly erroneous or contrary to law.31

“The standard of review for a magistrate judge’s report and recommendation is distinct from the standard of review that the magistrate judge applies to the Commissioner of Social Security’s decision regarding benefits.”32 The Court’s function on judicial review of the final decision of the Commissioner is limited to determining whether the Commissioner’s decision is supported by “substantial evidence” and whether the Commissioner applied the correct legal standard to evaluate the evidence.33 Substantial evidence is more than “a mere scintilla,” but less than a preponderance.34 This Court may not re-weigh the evidence, try the issues de novo, or substitute its judgment for the Commissioner’s.35 The ALJ is entitled to make any finding that is supported by substantial evidence, regardless of whether other conclusions are also permissible.36 “‘[N]o substantial evidence’ will be found only where there is a ‘conspicuous absence of credible

[evidentiary] choices’ or ‘no contrary medical evidence.’”37

30 See 28 U.S.C. § 636(b)(1) (“A judge of the court shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which an objection is made.”). 31 Id. 32 Muhleisen, 2024 WL 139525, at *4. 33 Audler v. Astrue, 501 F.3d 446, 447 (5th Cir. 2007). 34 Richardson v. Perales, 402 U.S. 389, 401 (1971); Hames v. Heckler, 707 F.2d 162, 164 (5th Cir. 1983). 35 Perez v. Barnhart, 415 F.3d 457, 461 (5th Cir. 2005). 36 See Arkansas v. Oklahoma, 503 U.S. 91, 113 (1992). 37 Johnson v. Bowen, 864 F.2d 340, 343-44 (5th Cir. 1988) (quoting Hames, 707 F.2d at 164). LAW AND ANALYSIS

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Richard v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-v-social-security-administration-laed-2025.