S.L. v. Commissioner of Social Security

CourtDistrict Court, S.D. Texas
DecidedDecember 17, 2025
Docket3:25-cv-00012
StatusUnknown

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

Bluebook
S.L. v. Commissioner of Social Security, (S.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT December 17, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk GALVESTON DIVISION S.L.,1 § § Plaintiff. § § V. § CIVIL ACTION NO. 3:25-cv-00012 § COMMISSIONER OF SOCIAL § SECURITY, § § Defendant. §

OPINION AND ORDER Plaintiff S.L. seeks judicial review of an administrative decision denying his applications for disability and disability insurance benefits under Title II, and for supplemental security income under Title XVI, of the Social Security Act (the “Act”). S.L. and Defendant Frank J. Bisignano, the Acting Commissioner of the Social Security Administration (the “Commissioner”),2 have submitted briefing addressing the factual and legal issues involved in this matter. See Dkts. 11, 15, and 18. After reviewing the briefing, the record, and the applicable law, I affirm the Commissioner’s decision. BACKGROUND On February 10, 2022, S.L. filed a Title II application for disability and disability insurance benefits, and a Title XVI application for supplemental security

1 On May 1, 2023, the Committee on Court Administration and Case Management of the Judicial Conference of the United States issued a memorandum recommending that courts adopt a local practice of using only the first name and last initial of any non- government party in Social Security opinions. This court has taken that guidance a step further in the interest of claimant’s privacy and will use only initials in public opinions. 2 Bisignano became the Commissioner of Social Security on May 7, 2025. Bisignano is “automatically substituted” as the defendant in this suit. Fed. R. Civ. P. 25(d); see also 42 U.S.C. § 405(g) (“Any action instituted in accordance with this subsection shall survive notwithstanding any change in the person occupying the office of Commissioner of Social Security or any vacancy in such office.”). income, alleging disability beginning February 1, 2022. His applications were denied and denied again upon reconsideration. Subsequently, an Administrative Law Judge (“ALJ”) held a hearing. Following the hearing, the ALJ issued a written decision finding that S.L. was not disabled. S.L. filed an appeal with the Appeals Council. The Appeals Council denied review, making the ALJ’s decision final and ripe for judicial review. APPLICABLE LAW The standard of judicial review for disability appeals is provided in 42 U.S.C. § 405(g). See Waters v. Barnhart, 276 F.3d 716, 718 (5th Cir. 2002). Courts reviewing the Commissioner’s denial of social security disability applications limit their analysis to “(1) whether the Commissioner applied the proper legal standards; and (2) whether the Commissioner’s decision is supported by substantial evidence on the record as a whole.” Est. of Morris v. Shalala, 207 F.3d 744, 745 (5th Cir. 2000). Addressing the evidentiary standard, the Fifth Circuit has explained: Substantial evidence is that which is relevant and sufficient for a reasonable mind to accept as adequate to support a conclusion; it must be more than a scintilla, but it need not be a preponderance. It is the role of the Commissioner, and not the courts, to resolve conflicts in the evidence. As a result, [a] court cannot reweigh the evidence, but may only scrutinize the record to determine whether it contains substantial evidence to support the Commissioner’s decision. A finding of no substantial evidence is warranted only where there is a conspicuous absence of credible choices or no contrary medical evidence. Ramirez v. Colvin, 606 F. App’x 775, 777 (5th Cir. 2015) (cleaned up). Judicial review is limited to the reasons relied on as stated in the ALJ’s decision, and post hoc rationalizations are not to be considered. See SEC v. Chenery Corp., 332 U.S. 194, 196 (1947). Under the Act, “a claimant is disabled only if she is incapable of engaging in any substantial gainful activity.” Anthony v. Sullivan, 954 F.2d 289, 293 (5th Cir. 1992) (quotation omitted). The Commissioner uses a five-step approach to determine if a claimant is disabled, including: (1) whether the claimant is presently performing substantial gainful activity; (2) whether the claimant has a severe impairment; (3) whether the impairment meets or equals a listed impairment; (4) whether the impairment prevents the claimant from doing past relevant work; and (5) whether the impairment prevents the claimant from performing any other substantial gainful activity. Salmond v. Berryhill, 892 F.3d 812, 817 (5th Cir. 2018) (quoting Kneeland v. Berryhill, 850 F.3d 749, 753 (5th Cir. 2017)). The burden of proof lies with the claimant during the first four steps before shifting to the Commissioner at Step 5. See Salmond, 892 F.3d at 817. Between Steps 3 and 4, the ALJ considers the claimant’s residual functional capacity (“RFC”), which serves as an indicator of the claimant’s maximum capabilities given the physical and mental limitations detailed in the administrative record. See Kneeland, 850 F.3d at 754. The RFC also helps the ALJ “determine whether the claimant is able to do her past work or other available work.” Id. THE ALJ’S DECISION The ALJ found at Step 1 that “there has been a continuous 12-month period(s) during which the claimant did not engage in substantial gainful activity.” Dkt. 8-3 at 18. The ALJ found at Step 2 that, S.L. “has the following severe impairments: coronary artery disease (CAD); internal carotid artery (ICA) disease; peripheral arterial disease (PAD); diabetes (DM); sleep apnea (OSA); obesity; anxiety; and depression.” Id. The ALJ also found that S.L’s vision issues were non-severe impairments. See id. After reviewing the “paragraph B” criteria at Step 3,3 the ALJ found that S.L. had a moderate limitation in concentrating, persisting, or maintaining pace

3 “The severity of ‘mental disorders’ is measured using medical criteria (‘paragraph A’), functional criteria (‘paragraph B’), and an analysis of ‘serious and persistent mental disorders’ (‘paragraph C’).” Vigil v. Berryhill, No. EP-17-cv-0242, 2018 WL 3233345, at (“CPP”), and mild limitations in understanding remembering or applying information; interacting with others; and adapting or managing oneself. See id. at 22. The ALJ found that none of S.L.’s impairments met any of the Social Security Administration’s listed impairments. See id. at 20. Prior to consideration of Step 4, the ALJ determined S.L.’s RFC as follows: [S.L.] has the residual functional capacity (RFC) to perform light work as defined in 20 CFR 404.1567(b) and 416.967(b) except he cannot climb ladders, ropes, or scaffolds. He can occasionally climb ramps and stairs, and occasionally balance, stoop, kneel, crouch, and crawl. He can frequently finger with bilateral upper extremities. He requires a cane to ambulate. He can understand, remember, and carryout detailed but not complex instructions. Id. at 23. At Step 4, the ALJ found that S.L. “is unable to perform any past relevant work.” Id. at 32. At Step 5, however, the ALJ found that S.L.

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Related

Estate of Morris v. Shalala
207 F.3d 744 (Fifth Circuit, 2000)
Waters v. Barnhart
276 F.3d 716 (Fifth Circuit, 2002)
Securities & Exchange Commission v. Chenery Corp.
332 U.S. 194 (Supreme Court, 1947)
Linda Ramirez v. Carolyn Colvin, Acting Cmsnr
606 F. App'x 775 (Fifth Circuit, 2015)
Olivia Kneeland v. Nancy Berryhill, Acting Cmsnr
850 F.3d 749 (Fifth Circuit, 2017)
Ronald Salmond, Sr. v. Nancy Berryhill, Acting Cms
892 F.3d 812 (Fifth Circuit, 2018)

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Bluebook (online)
S.L. v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sl-v-commissioner-of-social-security-txsd-2025.