Smith v. Appellate Operations

CourtDistrict Court, S.D. Texas
DecidedMarch 4, 2024
Docket4:23-cv-01953
StatusUnknown

This text of Smith v. Appellate Operations (Smith v. Appellate Operations) 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
Smith v. Appellate Operations, (S.D. Tex. 2024).

Opinion

UNITED STATES DISTRICT COURT March 04, 2024 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION DERRICK SMITH, § § Plaintiff. § § V. § CIVIL ACTION NO. 4:23-cv-01953 § COMMISSIONER OF SOCIAL § SECURITY, § § Defendant. §

MEMORANDUM AND RECOMMENDATION Plaintiff Derrick Smith (“Smith”) seeks judicial review of an administrative decision denying his application for supplemental security income benefits under Title XVI of the Social Security Act (the “Act”). Before me are briefs filed by Smith and Defendant Martin O’Malley, the Commissioner of the Social Security Administration (the “Commissioner”).1 See Dkts. 16, 19. After reviewing the briefing, the record, and the applicable law, I recommend the Commissioner’s decision be affirmed. BACKGROUND Smith filed an application for supplemental security income benefits on March 12, 2021, alleging disability beginning March 1, 2021. Smith’s application was denied and denied again upon reconsideration. On October 20, 2022, an Administrative Law Judge (“ALJ”) held a hearing. On November 8, 2022, the ALJ issued a decision finding that Smith has not been under a disability. The Appeals Council denied review, making the ALJ’s decision final and ripe for judicial review.

1 Martin O’Malley became the Commissioner of Social Security on December 20, 2023. O’Malley 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.”). 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 id. 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 At Step 1, the ALJ found that Smith “has not engaged in substantial gainful activity since March 12, 2021, the application date.” Dkt. 11-3 at 15. At Step 2, the ALJ found that Smith suffered from “the following severe impairments: mixed conductive and sensorineural hearing loss of the left ear and tinnitus.” Id. At Step 3, the ALJ found that Smith “does not have an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments.” Id. at 16. Prior to consideration of Step 4, the ALJ determined Smith’s RFC as follows: [Smith] can lift and carry ten pounds frequently and twenty pounds occasionally. [Smith] can stand and walk for six hours and sit for six hours of an eight-hour workday. [Smith] cannot be exposed to loud noises or machinery. Id. At Step 4, the ALJ found that Smith “has no past relevant work.” Id. at 18. Smith does, however, have “at least a high school education.” Id. The ALJ elicited testimony from a vocational expert (“VE”) that “there are jobs that exist in significant numbers in the national economy that [Smith] can perform.” Id. Based on the Medical-Vocational Rules, the ALJ explained that Smith “has not been under a disability” since his application date. Id. at 19. DISCUSSION Smith is representing himself in this appeal and raises four issues for review: (1) that it is “[h]ard finding reasonable paying jobs that makes training for 50+”; (2) that “[i]t’s very difficult to find meaningful employment after being convicted of bank robbery and serving 10yrs in prison”; (3) whether Smith meets the requirements of Listing 2.10; and (4) that Smith has degenerative disk disease. Dkt. 16 at 3. I am sympathetic to Smith’s situation, but as I explained at the hearing, even if I disagree with the ALJ’s ruling, I cannot reverse the Commissioner’s decision unless there is legal error or a lack of substantial evidence. I can only find that an ALJ’s ruling is unsupported by substantial evidence “where there is a conspicuous absence of credible choices or no contrary medical evidence.” Ramirez, 606 F. App’x at 777 (quotation omitted). The phrase “no contrary medical evidence” means that “[n]o medical evidence contradicts [the claimant’s disability].” Payne v. Weinberger, 480 F.2d 1006, 1008 (5th Cir. 1973). In plain language: as long as the ALJ followed the law, his reasoning makes sense, and there is some evidence to support his ruling, I must uphold the Commissioner’s decision, even if there is some evidence that suggests a disability. With this standard in mind, I will address each of the four issues Smith raises for review.

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Smith v. Appellate Operations, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-appellate-operations-txsd-2024.