Short v. Commissioner of Social Security

CourtDistrict Court, N.D. Texas
DecidedJune 18, 2025
Docket5:24-cv-00197
StatusUnknown

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

Bluebook
Short v. Commissioner of Social Security, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS LUBBOCK DIVISION

L.A.S.,1 § § Plaintiff, § § v. § 5:24-CV-197-H-BR § Commissioner, Social Security § Administration, § § Defendant. §

FINDINGS, CONCLUSIONS, AND RECOMMENDATION TO AFFIRM THE DECISION OF THE COMMISSIONER

Pursuant to 42 U.S.C. § 405(g), Plaintiff seeks judicial review of a decision by the Commissioner of Social Security (“Commissioner”), who denied Plaintiff’s applications for Title II2 disability insurance benefits and for Title XVI3 supplemental security income benefits under the Social Security Act (“the Act”). (ECF 1). Pursuant to the Northern District of Texas Special Order No. 30-350 (Sep. 11, 2023), this case was originally assigned to the undersigned United States Magistrate Judge to serve as presiding judge. (See ECF 5). Following notice to the Clerk of Court that one or more parties did not consent under 28 U.S.C. § 636(c) and Federal Rule of Civil Procedure 73(a), this case was then reassigned to the presiding United States District Judge and automatically referred for the

1 It is the undersigned’s practice to identify the plaintiff using only the first and last initial in filings in social security disability cases. This ensures that the public maintains access to the opinions (in compliance with Rule 5.2(c)(2)(B) of the Federal Rules of Civil Procedure and the E-Government Act of 2002) while still protecting the privacy of non- government parties’ identities within the opinion. 2 42 U.S.C. §§ 401–33. 3 42 U.S.C. §§ 1381–83f. undersigned to issue findings, conclusions, and recommendations (this “Recommendation”) to the presiding District Judge. After considering the filings and applicable law, the undersigned recommends that the Court AFFIRM the Commissioner’s decision. I. PROCEDURAL BACKGROUND Plaintiff filed the disputed applications in June of 2021 alleging disability beginning April

15, 2021. (ECF 9-1 at 232–44; see ECF 13 at 4). Plaintiff’s claims were denied initially, again upon reconsideration, and then again after a hearing before an Administrative Law Judge (“ALJ”). (ECF 9-1 at 122–228, see ECF 13 at 5). The Social Security Administration Appeals Council declined to review the ALJ’s decision, making it the final decision of the Commissioner. (ECF 9- 1 at 5–7; see ECF 13 at 6); see also 42 U.S.C. §§ 405(g), 1383(c)(3) (establishing the subject matter jurisdiction of United States District Courts to review final decisions of the Commissioner) and Kneeland v. Berryhill, 850 F.3d 749, 755 (5th Cir. 2017) (confirming that the Appeals Council declining to review an ALJ decision establishes that ALJ decision as final). II. STANDARD OF REVIEW A person may qualify for supplemental security income (“SSI”) or disability insurance

benefits (“DIB”) under the Act if they are disabled. 42 U.S.C. §§ 423(a)(1) (DIB) and id. at 1381a (SSI). A person is disabled according to the terms of the Act4 if they are 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. §§ 416(i)(1)(A), 423(d)(1)(A) (DIB) and

4 The Act is, for purposes of this Recommendation, entirely consistent across Title II provisions for DIB and Title XVI’s provisions for SSI. See, e.g., Barnhart v. Thomas, 540 U.S. 20, 23–24 (2003) (noting the identical definitions of “disability” in the two statutory programs). For completeness, this Recommendation will refer to the Act in general terms, but will cite to the distinct provisions applicable to DIB under Title II and SSI under Title XVI. id. at § 1382c(a)(3)(A) (SSI). “‘Substantial gainful activity’ is defined as a work activity involving significant physical or mental abilities for pay or profit.” Masterson v. Barnhart, 309 F.3d 267, 271 n.2 (5th Cir. 2002); accord 20 C.F.R. §§ 404.1572(a)–(b) (DIB) and 416.972(a)–(b) (SSI).5 ALJs use a standardized framework to determine whether an applicant is disabled under

the Act: In evaluating a disability claim, the [ALJ] conducts a five step sequential analysis to determine whether (1) the [plaintiff] is presently working; (2) the [plaintiff] has a severe impairment; (3) the impairment meets or equals an impairment listed in appendix 1 of the social security regulations; (4) the impairment prevents the [plaintiff] from doing past relevant work; and (5) the impairment prevents the [plaintiff] from doing any other substantial gainful activity. Audler v. Astrue, 501 F.3d 446, 447-48 (5th Cir. 2007). Before proceeding to steps four and five, the Commissioner must assess a claimant’s residual functional capacity (“RFC”). Perez v. Barnhart, 415 F.3d 457, 461 (5th Cir. 2005). RFC is defined as “the most [a claimant] can still do despite [the claimant’s] limitations.” 20 C.F.R. §§ 404.1545(a)(1) (DIB) and 416.945(a)(1) (SSI). The plaintiff bears the burden of proof in establishing a disability through the first four steps of the analysis; at the fifth step, the burden shifts to the ALJ and the Social Security Administration to show that there is other substantial work in the national economy that the plaintiff is capable of performing. Audler, 501 F.3d at 448; Copeland v. Colvin, 771 F.3d 920, 923 (5th Cir. 2014). A finding that the plaintiff is disabled or not disabled at any point in the five-step review is conclusive and terminates the analysis. Copeland, 771 F. 3d at 923 (citing Leggett v.

5 The Social Security Administration has the authority to promulgate regulations implementing the Act under 42 U.S.C. § 405(a) (DIB) and 42 U.S.C. § 1383b (SSI). In addition to traditional notice-and-comment regulations issued according to the Administrative Procedure Act, 5 U.S.C. § 553(b)–(c), the Social Security Administration also publishes precedential rulings and statements of policy or interpretation known as Social Security Rulings (each an “SSR”). 20 C.F.R. § 402

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Short v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/short-v-commissioner-of-social-security-txnd-2025.