Sedillos v. Social Security Administration

CourtDistrict Court, D. New Mexico
DecidedJune 25, 2025
Docket1:24-cv-00561
StatusUnknown

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

Bluebook
Sedillos v. Social Security Administration, (D.N.M. 2025).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

ANTHONY SEDILLOS,

Plaintiff, v. No. 1:24-cv-00561-JCH-LF

FRANK BISIGNANO, Commissioner of Social Security,1

Defendant.

MEMORANDUM OPINION AND ORDER I. Introduction This matter is before the Court on Plaintiff Anthony Sedillos’s Motion to Reverse and Remand to Agency with Supporting Memorandum (“Motion”) (ECF No. 15). Plaintiff alleges he became disabled on August 21, 2020, at age 35, because of post-traumatic stress disorder, anxiety, depression, hypertension, arthritis in both hands, and bipolar disease. Admin. R. 285, 320, ECF No. 11 (hereinafter “AR”). Plaintiff filed a Title II application for disability insurance benefits on November 6, 2020, and a Title XVI application for supplemental security income on December 7, 2020. AR 285, 292.

1 Frank Bisignano became the Commissioner of Social Security on May 6, 2025, and is automatically substituted as the defendant in this action. Fed. R. Civ. P. 25(d). Plaintiff’s applications were initially denied in March 2021, and denied upon reconsideration in June 2022. AR 159, 164, 176, 179. Plaintiff filed a request for hearing in July 2022, and Administrative Law Judge (“ALJ”) Leppala held a hearing on March 29, 2023. AR 186, 38. The ALJ issued his unfavorable decision on May 23, 2023. AR 15. Plaintiff requested review of the decision, but his request was denied in December 2023. AR 5. After receiving more time to

file a civil action in April 2024, Plaintiff filed the instant action on June 4, 2024, and this Motion on November 26, 2024. AR 1; Complaint 1, ECF No. 1; Mot. 1, ECF No. 15 (hereinafter “Mot.”). Defendant, the Commissioner of the Social Security Administration (“SSA”) (“Commissioner”), filed a brief in response to the Motion on February 24, 2025 (ECF No. 21), and on March 10, 2025, Plaintiff filed a reply in support of the Motion (ECF No. 22). Plaintiff argues first that the ALJ’s reliance upon the prior psychological administrative

findings is error because the findings do not constitute substantial evidence, and second that the ALJ picked and chose among moderate mental limitations noted by the psychological consultants.2 Mot. 1. Having meticulously reviewed the entire record and the relevant law, the Court finds that the ALJ did not err by relying on the psychological administrative findings and did not fail to adequately address Plaintiff’s moderate limitations. The Court will therefore DENY Plaintiff’s Motion. II. Applicable Law

A. Disability Determination Process

2 Plaintiff also argued that the ALJ erred by relying on Dr. Spoor’s prior administrative medical filings because he claimed that Dr. Spoor reviewed the concurrent claim only prior to the date last insured. Mot. 24. However, Plaintiff has since conceded this argument, recognizing that he was mistaken about the date last insured. See Resp. 19, ECF No. 21 (hereinafter “Resp.”); Reply 8, ECF No. 22 (hereinafter “Reply”). Accordingly, the Court does not address this argument. The SSA considers an individual disabled if the individual is unable “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). To make this determination, the SSA employs a five-step Sequential Evaluation Process (“SEP”). 20 C.F.R.

§ 404.1520; Fischer-Ross v. Barnhart, 431 F.3d 729, 731 (10th Cir. 2005). The process requires an ALJ to determine whether: (1) the plaintiff was engaged in substantial gainful activity during the alleged period of disability; (2) the plaintiff has a severe physical or mental impairment (or combination of impairments) that meets the duration requirement; (3) any such impairment meets or equals the severity of an impairment listed in Appendix 1 of 20 C.F.R. Part 404, Subpart P; (4) the plaintiff can return to her past relevant work; and, if not, (5) the plaintiff is able to perform other work in the national economy, considering her residual functional capacity (“RFC”), age, education, and work experience. 20 C.F.R. § 404.1520. If the plaintiff’s impairment meets or equals the severity of a listed impairment, as outlined in SEP step three, then the impairment is

conclusively presumed disabling. Bowen v. Yuckert, 482 U.S. 137, 146, n.5, (1987); Fischer-Ross, 431 F.3d at 731. If, however, the plaintiff is not considered disabled at SEP step three but has established a prima facie case of disability under SEP steps one, two, and four, then the burden shifts to the SSA at SEP step five to show the plaintiff can perform other work in the national economy considering the plaintiff’s RFC. Bowen, 482 U.S. at 146, n.5; Fischer-Ross, 431 F.3d at 731. State agency psychological consultants (“psychological consultants”) can be utilized

throughout the SEP to review a plaintiff’s records and submit opinions on a plaintiff’s medical condition. See 20 C.F.R § 404.1616. Although ALJs are not bound by these opinions, they must consider them and explain the weight given to them in their decisions. Keyes-Zachary v. Astrue, 695 F.3d 1156, 1161 (10th Cir. 2012) (“It is the ALJ’s duty to give consideration to all the medical opinions in the record [and] discuss the weight he assigns to such opinions.”).

Plaintiff’s arguments largely center around evaluation techniques utilized by psychological consultants at SEP steps two and three, and four and five. “The [Psychiatric Review Technique (“PRT”)] is used to assess mental impairments for purposes of steps two (identifying severe impairments) and three (rating severity for the listings).” Lull v. Colvin, 535 F. App’x 683, 686 (10th Cir. 2013); see generally 20 C.F.R. §§ 404.1520a, 416.920a. If it is determined that a plaintiff has a medically determinable impairment, then the degree of functional limitation resulting from the impairment is determined by rating the impact of the limitation on four broad functional areas: the ability to understand, remember, or apply information; interact with others; concentrate, persist,

or maintain pace; and adapt or manage oneself (the “B and C criteria”). 20 C.F.R. §§ 404.1520a, 416.920a. The Mental Residual Functional Capacity (“MRFC”) assessment, on the other hand, “addresses twenty specific mental functions relevant to the vocational determinations required at steps four and five.” Lull, 535 F. App’x at 686. While the limitations identified in the B and C criteria are used to rate the severity of mental impairment(s) at steps 2 and 3 of the SEP, the MRFC assessment used at steps 4 and 5 generally requires a more detailed assessment by itemizing

various functions contained in the four broad categories located in the B and C criteria of the adult mental disorders listings and summarized on the PRT. Id.

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Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Ramey v. Reinertson
268 F.3d 955 (Tenth Circuit, 2001)
Hamlin v. Barnhart
365 F.3d 1208 (Tenth Circuit, 2004)
Langley v. Barnhart
373 F.3d 1116 (Tenth Circuit, 2004)
Fischer-Ross v. Barnhart
431 F.3d 729 (Tenth Circuit, 2005)
Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Wheeler v. Commissioner
521 F.3d 1289 (Tenth Circuit, 2008)
Keyes-Zachary v. Astrue
695 F.3d 1156 (Tenth Circuit, 2012)
Lull v. Colvin
535 F. App'x 683 (Tenth Circuit, 2013)
Flaherty v. Astrue
515 F.3d 1067 (Tenth Circuit, 2008)
Carver v. Colvin
600 F. App'x 616 (Tenth Circuit, 2015)
Fulton v. Colvin
631 F. App'x 498 (Tenth Circuit, 2015)
Myers v. Astrue
870 F. Supp. 2d 1164 (D. Colorado, 2012)

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