Ryan v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedApril 16, 2025
Docket6:24-cv-00210
StatusUnknown

This text of Ryan v. Social Security Administration (Ryan 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
Ryan v. Social Security Administration, (E.D. Okla. 2025).

Opinion

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

ERIKA J. RYAN, ) ) ) Plaintiff, ) ) v. ) Case No. CIV-24-CV-210-SPS ) LELAND DUDEK, Acting ) Commissioner of the Social ) Security Administration, ) ) Defendant. )

OPINION AND ORDER

The claimant Erika J. Ryan, 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 AFFIRMED. 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 his physical or mental impairment or impairments are of such severity that he is not only unable to do his previous work but cannot, considering his 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.” Universal Camera Corp. v. NLRB, 340 U.S. 474, 488 (1951). See also Casias,

933 F.2d at 800-01.

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 his RFC does not preclude alternative work. See generally Williams v. Bowen, 844 F.2d 748, 750-51 (10th Cir. 1988). Procedural History The Court has jurisdiction under 42 U.S.C. § 405(g). Claimant was born on June 26, 1976, and was 41 years old on the alleged disability onset date. (Tr. 21). She has completed high school and has past relevant work as a nurse assistant. (Tr. 21, 53-53, 184). This case involves two

different applications for benefits, with two separate and distinct relevant time periods. Here, the administrative decision consists of two main findings. First, for purposes of the Title II claim for disability, the administrative law judge (ALJ) found Claimant was not disabled prior to her date last insured, December 31, 2017. (Tr. 556-57). Second, for purposes of the Title XVI claim, the ALJ found Claimant was disabled as of her application date, February 11, 2022, which was the earliest date she was entitled to disability under her Title XVI claim. (Tr. 556-57). See 20 C.F.R. § 416.335 (“[T]he earliest we can pay you benefits is the month following the month you filed the application”). Claimant contends the ALJ erred in finding her not disabled under Title II. However, Claimant must carry her burden to prove disability in 2017. Claimant applied for disability insurance benefits (DIB) under Title II of the Social

Security Act (the Act) in 2019, alleging disability as of May 2017. (Tr. 155). After an ALJ denied her application (Tr. 10-28), the decision was remanded for further evaluation of Dr. Keith Holder’s medical opinion. Claimant does not challenge the ALJ’s treatment of Dr. Holder’s opinion. In the interim, in February 2022, Claimant filed an additional application for supplemental security income (SSI) under Title XVI of the Act. (Tr. 880). On remand, the agency’s Appeals Council ordered the two claims consolidated. (Tr. 679). The ALJ held another hearing (Tr. 605-23) and found Claimant was not disabled for purposes of her Title II claim but became disabled in February 2022 for purposes of her Title XVI claim. (Tr. 556-57). See 20 C.F.R. § 404.984(d). Decision of the Administrative Law Judge The ALJ made her decision at step five of the sequential evaluation. At step two, the ALJ found that Claimant had severe physical impairments, but nonsevere mental impairments. (Tr. 543-545). She determined that, prior to February 11, 2022—the SSI application date—Claimant

had the residual functional capacity (RFC) to perform light work, except for frequent bilateral handling and fingering. (Tr. 546). See id. § 404.1545(a)(1) (“Your [RFC] is the most you can still do despite your limitations.”). At steps four and five, the ALJ found this RFC would allow Claimant to perform her past relevant work as a personal attendant, as well as other work existing in significant numbers in the national economy. (Tr.

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Ryan v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ryan-v-social-security-administration-oked-2025.