Thompson v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedAugust 12, 2025
Docket6:24-cv-00193
StatusUnknown

This text of Thompson v. Social Security Administration (Thompson 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
Thompson v. Social Security Administration, (E.D. Okla. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA AMANDA THOMPSON, o/b/o ) J.K.B., a minor child, ) ) Plaintiff, ) ) v. ) Case No. CIV-24-193-GLJ ) FRANK BISIGNANO,1 ) Commissioner of the Social ) Security Administration, ) ) Defendant. ) ORDER Claimant Amanda Thompson requests judicial review pursuant to 42 U.S.C. § 405(g) of the decision of the Commissioner of the Social Security Administration (“Commissioner”) denying benefits for her daughter J.K.B. under the Social Security Act. Claimant appeals the decision of the Commissioner and asserts that the Administrative Law Judge (“ALJ”) erred in determining J.K.B. was not disabled. For the reasons discussed below, the Commissioner’s decision should be REVERSED and the case REMANDED to the ALJ for further proceedings. I. Social Security Law and Standard of Review Disability for persons under the age of eighteen according to the Social Security Act is defined as a medically determinable physical or mental impairment or combination of 1 On May 7, 2025, Frank Bisignano became the Commissioner of Social Security. In accordance with Fed. R. Civ. P. 25(d), Mr. Bisignano is substituted for Michael O’Malley as the Defendant in this action. impairments that causes marked and severe functional limitations and that can be expected to cause death or that has lasted or can be expected to last for a continuous period of not

less than twelve months. See 20 C.F.R. § 416.906. Social Security Regulations implement a three-step sequential process to evaluate a claim for Child’s Supplemental Security Income Benefits under Title XVI of the Social Security Act.2 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.”

2 Step one requires claimant to establish the child is not engaged in substantial gainful activity, as defined by 20 C.F.R. §§ 416.971-416.976. Step two requires claimant to establish the child has an impairment or combination of impairments that is severe. If the child is engaged in substantial gainful activity or is found not to have a medically determinable impairment or the impairment causes a slight abnormality or combination of slight abnormalities resulting in no more than minimal functional limitations, she is considered not disabled. At step three, the child’s impairment must meet, medically equal, or functionally equal the severity of an impairment in the listing of impairments found in 20 C.F.R. Pt. 404, Subpt. P, App. 1. A child suffering from a listed impairment or impairments that meets or medically equals the requirements of the listing or that functionally equals the listing and meets the duration requirement will be found disabled. See 20 C.F.R. § 416.924(a)-(d)(2). Universal Camera Corp. v. NLRB, 340 U.S. 474, 488 (1951); see also Casias, 933 F.2d at 800-01.

II. Background and Procedural History J.K.B. was ten years old at the time of the administrative hearing. (Tr. 34). Claimant alleges J.K.B. was disabled as of August 1, 2018, due to attention deficit hyperactivity disorder (“ADHD”). (Tr. 211). On June 21, 2022, Claimant filed an application for supplemental security income benefits under Title XVI (42 U.S.C. § 1381 et seq.). Her application was denied. ALJ Bill Jones conducted an administrative hearing and

determined that J.K.B. was not disabled in a written opinion dated December 18, 2023. (Tr. 17-23). The Appeals Council denied review, so the ALJ’s findings represent the Commissioner’s final decision for purposes of this appeal. See 20 C.F.R. § 416.1481. III. Decision of the Administrative Law Judge The ALJ made his decision at step three of the sequential evaluation. He determined

J.K.B. had the severe impairment of ADHD, but that such impairments did not meet and were neither medically nor functionally equivalent to any of the relevant listings. (Tr. 18- 22). The ALJ thus concluded that J.K.B. was not disabled (Tr. 22). IV. Review Claimant contends that the ALJ failed to: (i) properly weigh J.K.B.’s subjective

complaints, (ii) properly defer to J.K.B.’s medical and school records, (iii) properly evaluate several of the domain impairments, and (iv) provide a substantive “whole child” analysis. The Court agrees that the ALJ failed to properly evaluate both the evidence in the record and the subjective statements, and the case should be remanded to the ALJ. A. Evidence in the Record The relevant medical evidence reveals that J.K.B. was diagnosed with ADHD and

prescribed medication for it, which required some dosage changes before the right prescription was reached because it reportedly wore off too fast as the day went on. (Tr. 245). Records reflect adjustments to J.K.B.’s prescription, and continued reports of being uncooperative at home even after she was considered controlled on medication. (Tr. 248). By August 2023, notes reflect that an increased dosage of her medication had been positive for her. (Tr. 279).

School records indicate that J.K.B. was not in special education classes and did not have an IEP. On August 15, 2022, J.K.B.’s teacher completed an evaluation in which she indicated that J.K.B. was one to two hours late for school 2-3 times per week, was several grade levels behind, but that J.K.B.’s functioning changed after she took her medication. (Tr. 164, 170). Although J.K.B. was in the fourth grade, her “actual” grade level was

assessed at 1.9. (Tr. 164). Additionally, she completed a questionnaire with numerous check boxes under each of the six domains of functioning, in which she indicates J.K.B.

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Thompson v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thompson-v-social-security-administration-oked-2025.