Ruckman v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedNovember 4, 2022
Docket6:21-cv-00264
StatusUnknown

This text of Ruckman v. Social Security Administration (Ruckman 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
Ruckman v. Social Security Administration, (E.D. Okla. 2022).

Opinion

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

ANGELINA RUCKMAN, ) ) Plaintiff, ) ) v. ) Case No. CIV-21-264-GLJ ) KILOLO KIJAKAZI, ) Acting Commissioner of the Social ) Security Administration, ) ) Defendant. )

OPINION AND ORDER The claimant Angelina Ruckman 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 discussed below, the Commissioner’s decision is hereby REVERSED and the case 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-one years old at the time of the administrative hearing (Tr. 35). She completed high school and has no past relevant work. (Tr. 22, 180). The claimant alleges that she has been unable to work since January 25, 2018, due to borderline personality disorder, post-traumatic stress disorder (“PTSD”), manic depression, and panic attacks. (Tr. 179).

Procedural History On May 12, 2019, the claimant applied for disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. §§ 401-434. Her application was denied. ALJ Edward M. Starr conducted an administrative hearing and determined that the claimant was not disabled in a written opinion dated January 29, 2021 (Tr. 12-23). The Appeals Council

denied review, so the ALJ’s opinion is the final decision of the Commissioner for purposes of this appeal. See 20 C.F.R. § 404.981. Decision of the Administrative Law Judge The ALJ made his decision at step five in this case. At steps two and three, he determined that the claimant had the severe impairments of depression, anxiety, personality

and impulse-control disorders, and trauma and stressor-related disorders, but that she did not meet a Listing. At step four, he found that the claimant had the residual functional capacity (“RFC”) to perform a full range of work at all exertional levels but with a number of nonexertional limitations, i.e., she could understand, recall, and perform tasks involving one or two steps; could focus for two hours with routine breaks and had the ability to pace and persist for an eight-hour workday and forty-hour workweek despite psychological

symptoms; could interact with co-workers and supervisors to learn tasks and accept criticism, but could not tolerate frequent interaction or frequent cooperation to complete work tasks; and could adapt to a work setting and some changes in work settings; but she was unable to interact appropriately or tolerate contact with the public (Tr. 17). The ALJ then found that although the claimant had no past relevant work to return to, she was nevertheless not disabled because there was work she could perform, e.g., poultry dresser,

laundry worker, and housekeeping cleaner (Tr. 22-23). Review The claimant contends that the ALJ erred in assessing the evidence related to her mental impairments. Specifically, she contends that the RFC assigned by the ALJ is inconsistent with the medical evidence. She further challenges the ALJ’s treatment of two

consultative physician opinions in the record, as well as his assessment of her subjective complaints. Finally, she contends that because the ALJ committed these errors at step four, his step five findings are also in error and require reversal.

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Ruckman v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ruckman-v-social-security-administration-oked-2022.