Rotondo v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedDecember 2, 2024
Docket2:24-cv-00005
StatusUnknown

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

Bluebook
Rotondo v. Commissioner of Social Security Administration, (D. Ariz. 2024).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Reed Rotondo, No. CV-24-00005-PHX-JAT

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 Pending before the Court is Plaintiff Reed Rotondo’s appeal from the Commissioner 16 of the Social Security Administration’s (“SSA,” “Commissioner,” or “Defendant,”) denial 17 of Social Security benefits. (Doc. 13). The appeal is fully briefed (Doc. 13; Doc. 17; Doc. 18 18), and the Court now rules. 19 I. BACKGROUND 20 The issues presented in this appeal are whether the ALJ committed materially 21 harmful error by (1) failing to include Plaintiff’s upper extremity limitations resulting from 22 his peripheral neuropathy in the RFC; (2) inappropriately dismissing RN Farmer’s 23 “medical opinion”; and (3) failing to meet her burden at Step Five in the sequential 24 disability evaluation process. (Doc. 13 at 4, 6, 7). 25 A. Factual Overview 26 Plaintiff was 37 years old on his alleged disability onset date. (Id. at 2). He has a 27 college education and a history of past relevant work as a commercial designer, technology 28 training coordinator, and vocational instructor. (Doc. 9-3 at 38). Plaintiff filed his disability 1 insurance benefits (DIB) application on May 12, 2020, alleging disabilities beginning on 2 April 29, 2020. (Doc. 13 at 1). On July 27, 2021, and March 4, 2022, Plaintiff testified in 3 telephonic hearings before an ALJ. (Id.) The ALJ denied Plaintiff’s claim on November 4, 4 2022. (Id. at 2). On November 6, 2023, the SSA Appeals Council denied Plaintiff’s request 5 for review of that decision and adopted the ALJ’s decision as the agency’s final decision. 6 (Id.) 7 B. The SSA’s Five-Step Evaluation Process 8 To qualify for social security disability insurance benefits, a claimant must show 9 that he “is under a disability.” 42 U.S.C. § 423(a)(1)(E). To be “under a disability,” the 10 claimant must be unable to engage in “substantial gainful activity” due to any medically 11 determinable physical or mental impairment. Id. § 423(d)(1). The impairment must be of 12 such severity that the claimant cannot do his previous work or any other substantial gainful 13 work within the national economy. Id. § 423(d)(2). The SSA has created a five-step 14 sequential evaluation process for determining whether an individual is disabled. See 20 15 C.F.R. § 404.1520(a)(1). The steps are followed in order, and each step is potentially 16 dispositive. See id. § 404.1520(a)(4). 17 At Step One, the ALJ determines whether the claimant is engaging in “substantial 18 gainful activity.” Id. § 404.1520(a)(4)(i). “Substantial gainful activity” is work activity that 19 is (1) “substantial,” i.e., doing “significant physical or mental activities”; and (2) “gainful,” 20 i.e., usually done “for pay or profit.” 20 C.F.R. § 416.972(a)–(b). If the claimant is engaging 21 in substantial gainful work activity, the ALJ will find the claimant is not disabled. Id. § 22 404.1520(a)(4)(i). 23 At Step Two, the ALJ determines whether the claimant has “a severe medically 24 determinable physical or mental impairment” or severe “combination of impairments.” Id. 25 § 404.1520(a)(4)(ii). To be “severe,” the claimant’s impairment must “significantly limit” 26 the claimant’s “physical or mental ability to do basic work activities.” Id. § 404.1520(c). 27 If the claimant does not have a severe impairment or combination of impairments, the ALJ 28 will find the claimant is not disabled. Id. § 404.1520(a)(4)(ii). 1 At Step Three, the ALJ determines whether the claimant’s impairment(s) “meets or 2 equals” an impairment listed in Appendix 1 to Subpart P of 20 C.F.R. Part 404. Id. § 3 404.1520(a)(4)(iii). If so, the ALJ will find the claimant is disabled, but if not, the ALJ 4 must assess the claimant’s “residual functional capacity” (“RFC”) before proceeding to 5 Step Four. Id. §§ 404.1520(a)(4)(iii), 404.1520(e). The claimant’s RFC is his ability 6 perform physical and mental work activities “despite his limitations,” based on all relevant 7 evidence in the case record. Id. § 404.1545(a)(1). To determine RFC, the ALJ must 8 consider all the claimant’s impairments, including those that are not “severe,” and any 9 related symptoms that “affect what [the claimant] can do in a work setting.” Id. §§ 10 404.1545(a)(1)–(2). 11 At Step Four, the ALJ determines whether the claimant has the RFC to perform the 12 physical and mental demands of “his past relevant work.” Id. §§ 404.1520(a)(4)(iv), 13 404.1520(e). “Past relevant work” is work the claimant has “done within the past 15 years, 14 that was substantial gainful activity.” Id. § 404.1560(b)(1). If the claimant has the RFC to 15 perform his past relevant work, the ALJ will find the claimant is not disabled. Id. § 16 404.1520(a)(4)(iv). If the claimant cannot perform his past relevant work, the ALJ will 17 proceed to Step Five in the sequential evaluation process. 18 At Step Five, the final step, the ALJ considers whether the claimant “can make an 19 adjustment to other work,” considering his RFC, age, education, and work experience. Id. 20 § 404.1520(a)(v). If so, the ALJ will find the claimant not disabled. Id. If the claimant 21 cannot make this adjustment, the ALJ will find the opposite. Id. 22 C. The ALJ’s Application of the Factors 23 Here, at Step One, the ALJ concluded that the record established that Plaintiff had 24 not engaged in substantial gainful activity since April 1, 2018, the alleged onset date. (Doc. 25 9-3 at 25). 26 At Step Two, the ALJ determined that Plaintiff had the following severe 27 impairments: “lumbar degenerative disc disease; Ehlers-Danlos syndrome, hypermobility 28 type; orthostatic hypotension; peripheral neuropathy; cannabinoid hyperemesis syndrome; 1 and protein S deficiency with history of superior mesenteric vein and subclavian vein 2 thromboses.” (Id.) 3 At Step Three, the ALJ found that Plaintiff did not have any impairment or 4 combination of impairments that met or medically equaled a listed impairment in Appendix 5 1 to Subpart P of 20 C.F.F. Part 404. (Id. at 29). Subsequently, the ALJ determined that 6 Plaintiff had the RFC to perform sedentary work as defined in 20 C.F.R. § 404.1567(a) and 7 416.967(a), except this person can lift and carry 20 pounds occasionally 8 and 10 pounds frequently, sit for 3 hours at a time and 7 hours 9 total out of an 8-hour day; stand for 1 hour at a time and 4 hours total out of an 8-hour day; and walk for 30 minutes at a time 10 and 2 hours total out of an 8-hour day. He can frequently 11 operate foot controls; occasionally climb ramps and stairs; never climb ladders, ropes, or scaffolds; occasionally balance, 12 stoop, kneel, crouch, and crawl; and frequently reach. This 13 individual must avoid concentrated exposure to extreme temperatures and vibration and even moderate exposure to 14 hazards, like dangerous moving machinery and unprotected 15 heights. He is able to understand, remember, and carry out simple instructions and make simple, work-related decisions in 16 a routine work setting, and perform tasks that do not involve 17 fast-paced production requirements, like those found in assembly line work or fast-food restaurants during mealtimes. 18 (Id. at 31). 19 At Step Four, the ALJ determined that Plaintiff was unable to perform any past 20 relevant work. (Id. at 38).

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Rotondo v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rotondo-v-commissioner-of-social-security-administration-azd-2024.