Trujillo v. Social Security Administration

CourtDistrict Court, D. New Mexico
DecidedMarch 31, 2025
Docket1:24-cv-00246
StatusUnknown

This text of Trujillo v. Social Security Administration (Trujillo 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
Trujillo v. Social Security Administration, (D.N.M. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW MEXICO

JOSE A T. JR.,

Plaintiff,

v. No. 1:24-cv-00246-JHR

LELAND DUDEK, Acting Commissioner of Social Security Administration,

Defendant.

MEMORANDUM OPINION AND ORDER GRANTING PLAINTIFF’S MOTION TO REVERSE AND REMAND [DOC. 13]

Before the Court is Plaintiff’s Motion to Reverse and Remand for a Rehearing with Supporting Memorandum [Doc. 13]. The Commissioner of the Social Security Administration filed a response [Doc. 19] and Plaintiff replied [Doc. 23]. Pursuant to 28 U.S.C. § 636(c) and Rule 73(b), the parties consented to the undersigned resolving Plaintiff’s motion to remand. [Doc. 4]. The Court has reviewed the parties’ briefing, the administrative record, [Doc. 10] (“AR”), and applicable law. The Court GRANTS Plaintiff’s motion to remand and REMANDS the matter for further proceedings. I. PROCEDURAL BACKGROUND Plaintiff protectively filed a Title XVI application for supplemental security income on March 20, 2019. (AR 106). The Commissioner denied his initial application on June 19, 2019, and again on November 7, 2019, upon reconsideration. (AR 135, 145). Plaintiff requested a hearing before an administrative law judge (“ALJ”). (AR 153). After the first hearing was held on November 10, 2020, ALJ Stephen Grontis found Plaintiff not disabled. (AR 14–34). The Appeals Council denied Plaintiff’s request for review, making the ALJ’s decision the final decision of the Commissioner and prompting Plaintiff to file an appeal in the District of New Mexico on August 18, 2021. (AR 1–4, 967–70). On August 30, 2022, U.S. Magistrate Judge Fashing reversed the Commissioner’s decision and remanded the matter due legal error arising from the ALJ discounting the opinion of consulting

psychologist Michael Mash, Ph.D. (AR 971, 987). Judge Fashing found two main errors. First, the ALJ failed to consider Dr. Mash’s treatment notes or other evidence supporting his opinion that Plaintiff had significant limitations from mental health issues. (AR 983) (“failure to examine the connection between Dr. Mash’s treatment records and his medical opinion is error”). She cited records denoting poor mental health symptoms as examples of such unexamined evidence. Id. Second, the ALJ improperly discounted Dr. Mash’s opinion based on a “mistake of fact”; the ALJ stated Dr. Mash evaluated Plaintiff in 2018 but in fact he assessed Plaintiff in 2019. Id. Judge Fashing explained this mistaken belief in year was harmful because it “resulted in the misunderstanding that Plaintiff was improving around the time of the alleged onset date and months after Dr. Mash’s assessment” when treatment notes supported that Plaintiff struggled with

his mental health “well after” the alleged onset date. (AR 985). She summarized that “[g]iven the ALJ’s mistaken belief that Dr. Mash’s opinion was from August 2018 rather than August 2019, and the evidence that [Plaintiff’s] symptoms worsened after August 2019” the ALJ’s evaluation of Dr. Mash’s opinion was not supported by substantial evidence and warranted remand. (AR 986). The Appeals Council then sent the case to a different ALJ for further proceedings consistent with Judge Fashing’s order. (AR 998–1000). Plaintiff appeared before ALJ Michelle Lindsay on September 6, 2023, for a rehearing at which a vocational witness also testified. (AR at 901-33). The ALJ again found Plaintiff not disabled in her written decision dated December 11, 2023. (AR 872–90). Plaintiff timely appealed the ALJ’s unfavorable decision on March 11, 2024. [Doc. 1]. II. STANDARD OF REVIEW When a party appeals an adverse disability decision the court must affirm if the ALJ applied correct legal standards and supported his factual findings with “substantial evidence.” Vigil v. Colvin, 805 F.3d 1199, 1201 (10th Cir. 2015) (quoting Mays v. Colvin, 739 F.3d 569, 571 (10th

Cir. 2014)). Review calls for common sense by setting aside technicalities in favor of whether the court can follow the ALJ’s reasoning and application of law. Keys-Zachary v. Astrue, 695 F.3d 1156, 1166 (10th Cir. 2012). Failure by the ALJ to follow legal standards will warrant reversal under appropriate circumstances “independent of the substantial evidence analysis.” Hendron v. Colvin, 767 F.3d 951, 954 (10th Cir. 2014) (quoting Glass v. Shalala, 43 F.3d 1392, 1395 (10th Cir. 1994)). At the same time, some errors may be harmless if the ALJ’s findings are sufficiently thorough and supported by the record. Allen v. Barnhart, 357 F.3d 1140, 1145 (10th Cir. 2004); Fischer-Ross v. Barnhart, 431 F.3d 729, 734 (10th Cir. 2005). Evidence is “substantial” when a reasonable mind would accept it as adequate support for the ALJ’s conclusion—more than a scintilla but less than a preponderance of the record. Lax v.

Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007). The court must examine the whole record to determine if the ALJ met the standard including any evidence that may undercut or detract from his findings. Flaherty v. Astrue, 515 F.3d 1067, 1070 (10th Cir. 2007). But the court may neither “reweigh the evidence nor substitute its judgment for that of the Commissioner’s." Lax, 489 F.3d at 1084 (quoting Hackett v. Barnhart, 395 F.3d 1168, 1172 (10th Cir. 2005)). The reviewing court must affirm, even if it would resolve the matter differently, unless the record overwhelms the ALJ’s factual findings or her decision rests on unsupported conclusions. Langley v. Barnhart, 373 F.3d 1116, 1118 (10th Cir. 2004). III. THE COMMISSIONER’S FINAL DECISION A claimant who seeks disability benefits under the Social Security Act must demonstrate that he cannot 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. § 423(d)(1)(A).

A five-step process guides whether the claimant satisfies that definition of disability. 20 C.F.R. § 404.1520(a)(4)(i)–(v).1 1 Those five steps address (1) whether the claimant is still engaged in substantial gainful activity; (2) whether the claimant is suffering from any impairments significantly limiting his ability to perform basic work activities; (3) whether those impairments meet or equal the criteria of a listed disabling impairment; (4) whether the claimant’s residual functional capacity (“RFC”), or his ability to sustain work-related activities regularly in a work setting, would preclude him from his past relevant work, and finally; (5) whether the claimant’s age, education, experience, and RFC would enable him to perform a substantial gainful activity existing in significant numbers in the national economy. Id.

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Watkins v. Barnhart
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Allen v. Barnhart
357 F.3d 1140 (Tenth Circuit, 2004)
Langley v. Barnhart
373 F.3d 1116 (Tenth Circuit, 2004)
Hackett v. Barnhart
395 F.3d 1168 (Tenth Circuit, 2005)
Fischer-Ross v. Barnhart
431 F.3d 729 (Tenth Circuit, 2005)
Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Oldham v. Astrue
509 F.3d 1254 (Tenth Circuit, 2007)
Keyes-Zachary v. Astrue
695 F.3d 1156 (Tenth Circuit, 2012)
Flaherty v. Astrue
515 F.3d 1067 (Tenth Circuit, 2008)
Mays v. Colvin
739 F.3d 569 (Tenth Circuit, 2014)
Hendron v. Colvin
767 F.3d 951 (Tenth Circuit, 2014)
Vigil v. Colvin
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Trujillo v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/trujillo-v-social-security-administration-nmd-2025.