Sands v. Social Security Administration

CourtDistrict Court, N.D. Iowa
DecidedAugust 27, 2024
Docket5:23-cv-04030
StatusUnknown

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

Bluebook
Sands v. Social Security Administration, (N.D. Iowa 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF IOWA WESTERN DIVISION

Jeffrey S., No. 23-cv-4030-CJW

Plaintiff, REPORT AND RECOMMENDATION

vs. MARTIN O’MALLEY, COMMISSIONER OF SOCIAL SECURITY, Defendant. ____________________

Jeffrey S. (“Claimant”) seeks judicial review of a final decision of the Commissioner of Social Security (“the Commissioner”) in denying his applications for disability insurance benefits (“DIB”) under Title II of the Social Security Act, 42 U.S.C. Sections 401-34 and for Supplemental Security Income benefits (“SSI”) under Title XVI of the Social Security Act, 42 U.S.C. Sections 1381-85. For the reasons that follow, I recommend that the Commissioner’s decision be affirmed. I. BACKGROUND Claimant was born in 1987. (AR1 at 91.) He has earned a GED in 2012. (Id. at 410.) Claimant allegedly became disabled due to right hand, right shoulder, right knee, and right foot problems, bipolar depression, lower back pain, allergies, anxiety, and ADHD. (Id. at 409.) Claimant’s alleged onset of disability date is May 8, 2016. (Id. at 19.) On November 20, 2018, Claimant filed his applications for DIB and SSI. (Id. at

1 “AR” cites refer to pages in the Administrative Record. 1 91-92). His claims were denied originally on August 28, 2019 (id. at 91-122) and were denied on reconsideration on January 27, 2020. (Id. at 123-58.) A telephonic hearing was held on April 6, 2022, with Claimant and his attorney James Greeman and Administrative Law Judge (“ALJ”) David G. Buell and Vocational Expert (“VE”) Steven Schill.2 (Id. at 19, 44-90.) Claimant and the VE both testified. (Id. at 49-88.) The ALJ issued an unfavorable decision on May 24, 2022. (Id. at 11-23.) Claimant requested review and the Appeals Council denied review on March 2, 2023. (Id. at 7-9.) Accordingly, the ALJ’s decision stands as the final administrative ruling in the matter and became the final decision of the Commissioner. See 20 C.F.R. §§ 404.981, 416.1481. On May 5, 2023, Claimant timely filed his Complaint in this Court. (Doc. 4.) On November 9, 2023, all briefing was completed, and the Honorable C.J. Williams, Chief United States District Court Judge, referred the case to me for a Report and Recommendation. II. DISABILITY DETERMINATIONS AND THE BURDEN OF PROOF A disability is 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 12 months.” 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). A claimant has a disability when, due to physical or mental impairments, the claimant: is not only unable to do [the claimant’s] previous work but cannot, considering [the claimant’s] age, education, and work experience, engage in any other kind of substantial gainful work which exists . . . in significant numbers either in the region where such individual lives or in several regions of the country.

2 Claimant consented to appear via telephone for the administrative hearing and waived his right to appear in person or via video. (AR at 47.) 2 42 U.S.C. §§ 423(d)(2)(A), 1382c(a)(3)(A). A claimant is not disabled if the claimant is able to do work that exists in the national economy but is unemployed due to an inability to find work, lack of options in the local area, technological changes in a particular industry, economic downturns, employer hiring practices, or other factors. 20 C.F.R. §§ 404.1566(c), 416.966(c). To determine whether a claimant has a disability, the Commissioner follows a five- step sequential evaluation process. Swink v. Saul, 931 F.3d 765, 769 (8th Cir. 2019). At steps one through four, the claimant has the burden to prove he or she is disabled; at step five, the burden shifts to the Commissioner to prove there are jobs available in the national economy. Moore v. Astrue, 572 F.3d 520, 523 (8th Cir. 2009). “If a claimant fails to meet the criteria at any step in the evaluation of disability, the process ends and the claimant is determined to be not disabled.” Pelkey v. Barnhart, 433 F.3d 575, 577 (8th Cir. 2006) (quotation omitted). At step one, the ALJ will consider whether a claimant is engaged in “substantial gainful activity.” Id. If so, the claimant is not disabled. 20 C.F.R. §§ 404.1520(a)(4)(i), 416.920(a)(4)(i). “Substantial activity is significant physical or mental work that is done on a full- or part-time basis. Gainful activity is simply work that is done for compensation.” Dukes v. Barnhart, 436 F.3d 923, 927 (8th Cir. 2006) (citing Comstock v. Chater, 91 F.3d 1143, 1145 (8th Cir. 1996); 20 C.F.R. §§ 404.1572(a)-(b), 416.972(a)-(b)). If the claimant is not engaged in substantial gainful activity, at step two, the ALJ decides if the claimant’s impairments are severe. 20 C.F.R. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). If the impairments are not severe, then the claimant is not disabled. Id. An impairment is not severe if it does not significantly limit a claimant’s “physical or mental ability to do basic work activities.” Id. §§ 404.1520(c), 416.920(c). The ability to do basic work activities means the ability and aptitude necessary to perform 3 most jobs. Bowen v. Yuckert, 482 U.S. 137, 141 (1987); see also 20 C.F.R. §§ 404.1521(b), 416.921(b). These include: (1) physical functions such as walking, standing, sitting, lifting, pushing, pulling, reaching, carrying, or handling; (2) capacities for seeing, hearing, and speaking; (3) understanding, carrying out, and remembering simple instructions; (4) use of judgment; (5) responding appropriately to supervision, co-workers, and usual work situations; and (6) dealing with changes in a routine work setting.

Id. (quotation omitted) (numbers added; internal brackets omitted). If the claimant has a severe impairment, at step three, the ALJ will determine the medical severity of the impairment. 20 C.F.R. §§ 404.1520(a)(4)(iii), 416.920(a)(4)(iii). If the impairment meets or equals one of the impairments listed in the regulations (“the listings”), then “the claimant is presumptively disabled without regard to age, education, and work experience.” Tate v. Apfel, 167 F.3d 1191, 1196 (8th Cir. 1999) (quotation omitted).

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Bluebook (online)
Sands v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sands-v-social-security-administration-iand-2024.