Richard v. Social Security Administration

CourtDistrict Court, M.D. Louisiana
DecidedJune 24, 2025
Docket3:24-cv-00496
StatusUnknown

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

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

Opinion

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF LOUISIANA

RYAN CHRISTOPHER RICHARD CIVIL ACTION

VERSUS NO. 24-496-RLB

COMMISSIONER, SOCIAL SECURITY ADMINISTRATION

ORDER Ryan Christopher Richard (“Plaintiff”) seeks judicial review of a final decision of the Commissioner of the Social Security Administration (the “Commissioner”) pursuant to 42 U.S.C. § 405(g). (R. Doc. 1). Having found all the procedural prerequisites met, this Court has properly reviewed Plaintiff’s appeal. See 42 U.S.C. § 405(g); see also 20 C.F.R. § 404.981. For the reasons given below, the Court orders that the Commissioner’s decision be VACATED and that Plaintiff’s appeal be REMANDED for further proceedings consistent with this Order. I. PROCEDURAL HISTORY On September 3, 2020, Plaintiff filed a Title II application for disability benefits, and on September 22, 2020, Plaintiff filed a Title XVI application for supplemental security income. (Tr. 208; 210; 423; 473). Plaintiff alleged his disability—a combination of discogenic and degenerative back problems, depression, and anxiety—had a date of onset of March 31, 2020. (Tr. 473; 488; 513; 516). Although it was recognized that Plaintiff’s impairments were spine disorders and depressive, bipolar, and related disorders, Plaintiff’s claims were denied initially on August 9, 2021, and were denied again, upon reconsideration, on July 21, 2022. (Tr. 183; 191; 212). As a result, Plaintiff filed a request for a hearing on July 27, 2022, and it was set for December 7, 2022. (Tr. 270; 316). Administrative Law Judge Charlotte White (“Judge White”) attempted to conduct the hearing on December 7, 2022, but it was rescheduled to January 4, 2023 due to technical difficulties. (Tr. 104; 122; 124). At the January 4, 2023 hearing, Plaintiff’s attorney alleged a new onset date of August 7, 2019. (Tr. 89). Following this hearing, however, Judge White became unavailable, and the case was reassigned to Judge Michael Hertzig (“Judge Hertzig”). (Tr. 56-57). Judge Hertzig held a supplemental hearing on August 23, 2023, but, as Plaintiff failed to attend, it was eventually rescheduled to October 26, 2023. (Tr. 24; 56).

Plaintiff, Plaintiff’s attorney, Ashok Khushalani, MD (“Dr. Khushalani”), and vocational expert Kasey Crawford appeared at the hearing on October 26, 2023. (Tr. 24). Judge Hertzig published his decision on December 18, 2023, holding that, although Plaintiff had severe major depressive disorder, recurrent generalized anxiety disorder, alcohol use disorder, and disorders of the spine, Plaintiff was not disabled because Plaintiff was found to be capable of working when he stopped abusing drugs. (Tr. 130-151). The Appeals Council, on April 19, 2024, denied Plaintiff’s January 15, 2024 request for review of the December 18, 2023 Administrative Law Judge (“ALJ”) decision. (Tr. 1; 5). Plaintiff filed his Complaint on June 18, 2024 (R. Doc. 1). II. STANDARD OF REVIEW

The Court’s review of the Commissioner’s decision is limited under 42 U.S.C. § 405(g) to two inquiries: (1) whether there is substantial evidence to support the findings of the ALJ and (2) whether the correct legal standards were applied. See Anthony v. Sullivan, 954 F.2d 289, 292 (5th Cir. 1992); see also Villa v. Sullivan, 895 F.2d 1019, 1021 (5th Cir. 1990). Substantial evidence is defined as less than a preponderance but “more than a mere scintilla.” Bowling v. Shalala, 36 F.3d 431, 434 (5th Cir. 1994). It means “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Villa, 895 F.2d at 1022. The Fifth Circuit has held that substantial evidence “must do more than create a suspicion of the existence of the fact to be established, but no substantial evidence will be found only where there is a conspicuous absence of credible choices or no contrary medical evidence.” Hames v. Heckler, 707 F.2d 162, 164 (5th Cir. 1983) (quotations and citations omitted). The Court may not reweigh evidence, try issues de novo, or substitute its judgment for that of the Commissioner. See Cook v. Heckler, 750 F.2d 391, 392 (5th Cir. 1985). Conflicts in the evidence are for the Commissioner “and not the courts to resolve.” Selders v. Sullivan, 914 F.2d 614, 617 (5th Cir. 1990). If the Commissioner’s

decision is supported by substantial evidence, then it is conclusive and must be upheld. See Estate of Morris v. Shalala, 207 F.3d 744, 745 (5th Cir. 2000) (quoting 42 U.S.C. § 405 (g)). If, on the other hand, the Commissioner fails to apply the correct legal standards, or fails to provide a reviewing court with a sufficient basis to determine that the correct legal principles were followed, it is grounds for reversal. See Bradley v. Bowen, 809 F.2d 1054, 1057 (5th Cir. 1987). III. ALJ’S DETERMINATION To qualify for benefits, the claimant must establish that he is disabled within the meaning of the Social Security Act (the “SSA”). See Herron v. Bowen, 788 F.2d 1127, 1131 (5th Cir. 1986). The SSA defines disability as the “inability 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.” Selders, 914 F.2d at 618. The Commissioner (through an ALJ) applies a five-step sequential analysis to determine whether a claimant is disabled. See 20 C.F.R. § 404.1520(a)(4). First, the claimant must prove he is not currently engaged in substantial gainful activity. See 20 C.F.R. § 404.1520(b). Second, the claimant must prove his impairment is “severe” in that it “significantly limits [his] physical or mental ability to do basic work activities[.]” 20 C.F.R. § 404.1520(c). At step three, the ALJ must conclude the claimant is disabled if he proves his impairments meet or are medically equivalent to one of the impairments contained in the Listing of Impairments. See 20 C.F.R. § 404

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Estate of Morris v. Shalala
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986 F.3d 551 (Fifth Circuit, 2021)

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