Strickland v. Commissioner of Social Security

CourtDistrict Court, E.D. Texas
DecidedMarch 14, 2025
Docket6:23-cv-00502
StatusUnknown

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

Bluebook
Strickland v. Commissioner of Social Security, (E.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS No. 6:23-cv-00502 Barry Strickland, Plaintiff, v. Commissioner of the Social Security Administration, Defendant.

ORDER AND OPINION Plaintiff filed this civil action pursuant to the Social Security Act, 42 U.S.C. § 405(g), seeking judicial review of the Commis- sioner’s denial of his application for Social Security benefits. The case was referred to a magistrate judge, who issued a report rec- ommending that the decision of the Commissioner be affirmed and that this cause of action be dismissed with prejudice. Doc. 17. Plaintiff timely objected. Doc. 18. The court reviews the objected-to portions of a report and rec- ommendation de novo. 28 U.S.C. § 636(b)(1). In conducting a de novo review, the court examines the entire record and makes an independent assessment under the law. Douglass v. United Servs. Auto. Ass’n, 79 F.3d 1415, 1430 (5th Cir. 1996) (en banc), super- seded on other grounds by 28 U.S.C. § 636(b)(1) (extending the time to file objections from 10 to 14 days). The court reviews all unob- jected-to portions of the report and recommendation only for clear error or abuse of discretion. See United States v. Wilson, 864 F.2d 1219, 1221 (5th Cir. 1989) (noting that, if no objections to a magistrate judge’s report are filed, the standard of review is “clearly erroneous, abuse of discretion and contrary to law”). Plaintiff begins by objecting to the report “in its entirety.” Doc. 18 at 2. However, generalized objections that do not identify specific sections of the report and the basis for objection are in- sufficient to trigger de novo review. See Bush v. Monroe, No. 6:17- cv-00541, 2018 WL 4042418, at *1 (E.D. Tex. Aug. 24, 2018)

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(citing Battle v. U.S. Parole Comm’n, 834 F.2d 419, 421 (5th Cir. 1987)). Therefore, this blanket objection is overruled. Plaintiff next objects to the magistrate judge’s finding that the ALJ performed an adequate consistency analysis of Dr. Combs’s opinion. Doc. 18 at 2. Plaintiff contends that the ALJ performed a consistency analysis of Dr. Combs’s opinion only with respect to plaintiff’s capacity for adapting and managing and therefore left a reviewing court to do guesswork on the remainder of the assessed work limitations. Id. at 2–5. Here, consultative examiner Dennis Combs, Ph.D., opined that claimant would have no impairment understanding, remem- bering, and carrying out one- to two-step tasks; had a mild impair- ment in relating to supervisors, coworkers and the public; had no impairment with concentration, persistence, and pace; and had a moderate impairment in adapting and managing himself. Doc. 11- 3 at 23–24. The ALJ, however, pointed out that this opinion was partially contradicted by “Dr. Combs’ own evaluation and is in- consistent with the evidence of record for Dr. Comb’s [sic] nota- tion of a moderate impairment in adapting with examinations showing the claimant appeared with appropriate affect and de- meanor, was alert and fully oriented with appropriate speech, a neat and clean appearance, and cooperative.” Id. at 24. While this inconsistency was specifically noted in the context of the limitation in adapting and managing, the record reflects that the ALJ did a consistency analysis for the entirety of Dr. Combs’s opinion. Specifically, the ALJ extensively cited the medical rec- ords in discussing the supportability and consistency of Dr. Combs’s opinions and stated where she found them to be incon- sistent, which simply happened to be only with respect to the adapting and managing limitations. Id. Notably, where Dr. Combs found no limitations, for example in carrying out one- to two-step tasks, the ALJ specifically noted those conclusions in her con- sistency analysis. Id. at 23–24; Doc. 11-8 at 163. The court thus finds that plaintiff’s objection on this point is unfounded as the ALJ performed a legally adequate consistency analysis. However, plaintiff’s final objection has more merit. Plaintiff suggests that the one- to two-step task limitation discussed by the ALJ should have been included in the Residual Functional Capac- ity (RFC) assessment and that this would have precluded semi- skilled past work relied on by the ALJ. Doc. 18 at 5–8. At the out- set, this court notes that the ALJ only found Dr. Combs’s opin- ion—including the one- to two-step task limitation—to be “par- tially persuasive.” Doc. 11-3 at 24. It is thus unclear whether the ALJ found at step two that plaintiff was strictly unable to carry out tasks with more than one to two steps. Nevertheless, the ALJ’s limited RFC analysis regarding plaintiff’s mental capacity warrants further scrutiny. To determine whether a claimant is disabled, the Commis- sioner engages in the following five-step sequential analysis: 1) An individual who is working and engaging in sub- stantial gainful activity will not be found disabled regardless of the medical findings. 2) An individual who does not have a “severe impair- ment” will not be found to be disabled. 3) An individual who meets or equals a listed impair- ment in Appendix 1 of the regulations will be con- sidered disabled without consideration of voca- tional factors. 4) If an individual is capable of performing the work he has done in the past, a finding of “not disabled” must be made. 5) If an individual’s impairment precludes him from performing his past work, other factors including age, education, past work experience, and residual functional capacity must be considered to deter- mine if other work can be performed. Villa v. Sullivan, 895 F.2d 1019, 1022 (5th Cir. 1990) (paraphras- ing 20 C.F.R. § 404.1520(b)–(f)). “A disability determination at any point in the five-step process is conclusive and terminates any further analysis.” Id. Furthermore, if an impairment is severe at step two but does not reach the level of a listed disordered at step three, the ALJ must perform an RFC assessment—in other words, an analysis of the most work a claimant can do given all his impairments. See Boyd v. Apfel, 239 F.3d 698, 705 (5th Cir. 2001). Here, at step two, the ALJ determined that plaintiff has no “more than ‘mild’ limitation” in any of the four areas of mental functioning. Doc. 11-3 at 24. Specifically, she found mild limita- tions in plaintiff’s ability to understand, remember, or apply in- formation and in his ability to adapt and manage himself. The ALJ ultimately concluded in step two that these mild limitations were non-severe pursuant to 20 C.F.R. § 404.1520a(d)(1). Id. The ALJ, however, did find severe physical limitations—including lumbar degenerative disc disease, coronary artery disease, and obesity— and thus proceeded past step two. Id. at 21. In the subsequent RFC assessment, the ALJ did not analyze how these minor limitations might affect plaintiff’s work capabil- ity.

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Strickland v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/strickland-v-commissioner-of-social-security-txed-2025.