Snider v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedFebruary 12, 2025
Docket6:24-cv-00059
StatusUnknown

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

Bluebook
Snider v. Social Security Administration, (E.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

JOHN NICHOLAS SNIDER, ) ) Plaintiff, ) ) v. ) Case No. CIV-24-059-RAW-SPS ) MICHELLE A. KING, ) Acting Commissioner of the ) Social Security Administration, ) ) Defendant. )

REPORT AND RECOMMENDATION

The claimant John Nicholas Snider, requests judicial review of a denial of benefits by the Commissioner of the Social Security Administration pursuant to 42 U.S.C. § 405(g). He appeals the Commissioner’s decision and asserts that the Administrative Law Judge (“ALJ”) erred in determining he was not disabled. For the reasons discussed below, the Magistrate Judge recommends the Commissioner’s decision be AFFIRMED. I. Social Security Law and Standard of Review Disability under the Social Security Act is defined as the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment[.]” 42 U.S.C. § 423(d)(1)(A). A claimant is disabled under the Social Security Act “only if his physical or mental impairment or impairments are of such severity that he is not only unable to do his previous work but cannot, considering his age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy[.]” Id. § 423 (d)(2)(A). Social security regulations implement a five-step sequential process to evaluate a disability claim. See 20 C.F.R. §§ 404.1520, 416.920.1 Section 405(g) limits the scope of judicial review of the Commissioner’s decision to two inquiries: whether the decision was supported by substantial evidence and whether correct legal

standards were applied. See Hawkins v. Chater, 113 F.3d 1162, 1164 (10th Cir. 1997). Substantial evidence is “‘more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Richardson v. Perales, 402 U.S. 389, 401 (1971) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). See also Clifton v. Chater, 79 F.3d 1007, 1009 (10th Cir. 1996). The Court may not reweigh the evidence or substitute its discretion for the Commissioner’s. See Casias v. Secretary of Health & Human Services, 933 F.2d 799, 800 (10th Cir. 1991). But the Court must review the record as a whole, and “[t]he substantiality of evidence must take into account whatever in the record fairly detracts from its weight.” Universal Camera Corp. v. NLRB, 340 U.S. 474, 488 (1951). See also Casias,

933 F.2d at 800-01.

1 Step one requires the claimant to establish that he is not engaged in substantial gainful activity. Step two requires the claimant to establish that he has a medically severe impairment (or combination of impairments) that significantly limits his ability to do basic work activities. If the claimant is engaged in substantial gainful activity, or his impairment is not medically severe, disability benefits are denied. If he does have a medically severe impairment, it is measured at step three against the listed impairments in 20 C.F.R. Part 404, Subpt. P, App. 1. If the claimant has a listed (or “medically equivalent”) impairment, he is regarded as disabled and awarded benefits without further inquiry. Otherwise, the evaluation proceeds to step four, where the claimant must show that he lacks the residual functional capacity (“RFC”) to return to his past relevant work. At step five, the burden shifts to the Commissioner to show there is significant work in the national economy that the claimant can perform, given his age, education, work experience, and RFC. Disability benefits are denied if the claimant can return to any of his past relevant work or if his RFC does not preclude alternative work. See generally Williams v. Bowen, 844 F.2d 748, 750-51 (10th Cir. 1988). II. Background and Procedural History Claimant was born on October 16, 1981, and was 40 years old on the alleged disability onset date. (Tr. 33). He was 42 years old at the time of the most recent administrative hearing. (Tr. 44). He has completed high school and has past relevant work experience as a general manager

and military officer. (Tr. 32). Claimant asserts he has been unable to work since November 10, 2021. (Tr. 19, 158). Claimant applied for disability insurance benefits (DIB) under Title II of the Social Security Act (the Act) in 2022. (Tr. 155-59). The ALJ’s decision denying his application became the Commissioner’s final decision when the agency’s Appeals Council denied his request for review. (Tr. 17-34). III. Decision of the Administrative Law Judge The ALJ made her decision at step five of the sequential evaluation. At step two, the ALJ found that Claimant had severe impairments including posttraumatic stress disorder (PTSD); depressive disorder; anxiety disorder, with related tremors/tic disorder; osteoarthritis and

tendinopathy of the right shoulder, status post arthroscopy. (Tr. 20). The ALJ also found Claimant suffered from the nonsevere impairment of obesity. Id. Next, she found that Claimant’s impairments did not meet a listing. Id. At step four, she found that Claimant was unable to perform any past relevant work, but retained “the residual functional capacity (“RFC”) to perform less than the full range of medium work with the following qualifications: Over the course of an 8-hour workday with standard (i.e., morning, lunch and afternoon, or the equivalent) work breaks, he can lift, carry, push and pull up to 50 pounds occasionally and 25 pounds frequently; sit 6 hours; stand and walk for a combined total of 6 hours; never climb ladders, ropes or scaffolds or otherwise work at unprotected heights; not perform work involving commercial driving or operating heavy machinery; with the right upper extremity, can reach frequently but not constantly; and handle and finger frequently but not constantly with the bilateral upper extremities. He can work in no more than a moderate noise environment. He can sustain attention and concentration for simple work tasks and make simple work-related decisions; occasionally interact with coworkers and supervisors for incidental work purposes, but not work with the public or perform team or tandem tasks; and deal with occasional changes in a routine work setting.

(Tr. 22). At step five, the ALJ found that this RFC would allow Claimant to perform other work existing in significant numbers in the national economy. (Tr. 34). The ALJ thus concluded that Claimant was not disabled under the Act. Id. IV.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Snider v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/snider-v-social-security-administration-oked-2025.