Snyder v. Social Security Administration

CourtDistrict Court, D. New Mexico
DecidedFebruary 3, 2020
Docket1:19-cv-00115
StatusUnknown

This text of Snyder v. Social Security Administration (Snyder 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
Snyder v. Social Security Administration, (D.N.M. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF NEW MEXICO

CHARLES W. SNYDER,

Plaintiff,

v. No. 19-cv-0115 SMV

ANDREW SAUL,1 Commissioner of the Social Security Administration,

Defendant.

MEMORANDUM OPINION AND ORDER

THIS MATTER is before the Court on Plaintiff’s Motion to Reverse and Remand for a Rehearing with Supporting Memorandum [Doc. 19], filed on June 21, 2019. The Commissioner responded on September 19, 2019. [Doc. 22]. Plaintiff replied on November 1, 2019. [Doc. 27]. The parties have consented to my entering final judgment in this case. [Doc. 9]. Having meticulously reviewed the entire record and being fully advised in the premises, the Court finds that Plaintiff fails to show that the Administrative Law Judge (“ALJ”) either applied an incorrect standard of law or that his findings were not supported by substantial evidence. That is, Plaintiff fails to show any reversible error in the ALJ’s evaluation of the Dr. Draper’s opinion, Dr. Greene’s opinion, or Plaintiff’s own subjective-symptom allegations. The Motion will be denied, and the Commissioner’s final decision, affirmed.

1 Andrew Saul is the current Commissioner of Social Security. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Andrew Saul should be substituted for Acting Commissioner Nancy A. Berryhill as the Defendant in this suit. No further action needs to be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g). Standard of Review The standard of review in a Social Security appeal is whether the Commissioner’s final decision2 is supported by substantial evidence and whether the correct legal standards were applied. Maes v. Astrue, 522 F.3d 1093, 1096 (10th Cir. 2008). If substantial evidence supports the Commissioner’s findings and the correct legal standards were applied, the Commissioner’s decision stands and the plaintiff is not entitled to relief. Langley v. Barnhart, 373 F.3d 1116, 1118 (10th Cir. 2004). Courts must meticulously review the entire record but may neither reweigh the evidence nor substitute their judgment for that of the Commissioner. Flaherty v. Astrue, 515 F.3d 1067, 1070 (10th Cir. 2007). “Substantial evidence is such relevant evidence as a reasonable mind might accept as

adequate to support a conclusion.” Langley, 373 F.3d at 1118. The decision “is not based on substantial evidence if it is overwhelmed by other evidence in the record or if there is a mere scintilla of evidence supporting it.” Id. While a court may not reweigh the evidence or try the issues de novo, its examination of the record as a whole must include “anything that may undercut or detract from the [Commissioner]’s findings in order to determine if the substantiality test has been met.” Grogan v. Barnhart, 399 F.3d 1257, 1262 (10th Cir. 2005). “The possibility of drawing two inconsistent conclusions from the evidence does not prevent [the] findings from being

2 A court’s review is limited to the Commissioner’s final decision, 42 U.S.C. § 405(g), which generally is the ALJ’s decision, 20 C.F.R. § 416.1481 (1980). The Tenth Circuit, however, has held that in some situations, a court must consider evidence beyond that which was before the ALJ. See Martinez v. Barnhart, 444 F.3d 1201, 1207−08 (10th Cir. 2006); O’Dell v. Shalala, 44 F.3d 855, 859 (10th Cir. 1994). Pursuant to the regulations, any new and material evidence that relates to the period on or before the date of the ALJ’s decision must be considered by the Appeals Council in determining whether to review the ALJ’s decision. 20 C.F.R. § 416.1468 (2017); 20 C.F.R. § 416.1470(b) (1987). Although Plaintiff initially challenged the Appeals Council’s handling of certain evidence, [Doc. 19] at 15– 19, he later withdrew his challenge, [Doc. 27] at 1. Accordingly, this case fits the general framework, and the Court reviews the ALJ’s decision as the Commissioner’s final decision. 2 supported by substantial evidence.” Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007) (quoting Zoltanski v. FAA, 372 F.3d 1195, 1200 (10th Cir. 2004)). The “failure to apply the correct legal standard or to provide this court with a sufficient basis to determine that appropriate legal principles have been followed is grounds for reversal.” Jensen v. Barnhart, 436 F.3d 1163, 1165 (10th Cir. 2005) (quoting Byron v. Heckler, 742 F.2d 1232, 1235 (10th Cir. 1984)). Applicable Law and Sequential Evaluation Process In order to qualify for disability benefits, a claimant must establish that he 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. § 1382c(a)(3)(A) (2015); 20 C.F.R. § 416.905(a) (2012). When considering a disability application, the Commissioner is required to use a five-step sequential evaluation process. 20 C.F.R. § 416.920 (2012); Bowen v. Yuckert, 482 U.S. 137, 140 (1987). At the first four steps of the evaluation process, the claimant must show: (1) he is not engaged in “substantial gainful activity”; and (2) he has a “severe medically determinable . . . impairment . . . or a combination of impairments” that has lasted or is expected to last for at least one year; and (3) his impairment(s) either meet or equal one of the Listings3 of presumptively disabling impairments; or (4) he is unable to perform his “past relevant work.” 20 C.F.R. § 416.920(a)(4)(i)–(iv); see Grogan, 399 F.3d at 1261. If he cannot show that his impairment

3 20 C.F.R. pt. 404, subpt. P, app. 1.

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Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Doyal v. Barnhart
331 F.3d 758 (Tenth Circuit, 2003)
Watkins v. Barnhart
350 F.3d 1297 (Tenth Circuit, 2003)
Zoltanski v. Federal Aviation Administration
372 F.3d 1195 (Tenth Circuit, 2004)
Langley v. Barnhart
373 F.3d 1116 (Tenth Circuit, 2004)
Grogan v. Barnhart
399 F.3d 1257 (Tenth Circuit, 2005)
Haga v. Barnhart
482 F.3d 1205 (Tenth Circuit, 2007)
Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Maes v. Astrue
522 F.3d 1093 (Tenth Circuit, 2008)
Chapo v. Astrue
682 F.3d 1285 (Tenth Circuit, 2012)
Keyes-Zachary v. Astrue
695 F.3d 1156 (Tenth Circuit, 2012)
Wells v. Astrue
727 F.3d 1061 (Tenth Circuit, 2013)
Flaherty v. Astrue
515 F.3d 1067 (Tenth Circuit, 2008)
Lewis v. Berryhill
680 F. App'x 646 (Tenth Circuit, 2017)

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