Tyke Fontenot v. Commissioner of Social Security

CourtDistrict Court, M.D. Louisiana
DecidedMarch 6, 2026
Docket3:24-cv-00907
StatusUnknown

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

Bluebook
Tyke Fontenot v. Commissioner of Social Security, (M.D. La. 2026).

Opinion

UNITED STATES DISTRICT COURT

MIDDLE DISTRICT OF LOUISIANA

TYKE FONTENOT CIVIL ACTION

VERSUS NO. 24-907-SDD-SDJ

COMMISSIONER OF SOCIAL SECURITY

NOTICE Please take notice that the attached Magistrate Judge’s Report has been filed with the Clerk of the U.S. District Court.

In accordance with 28 U.S.C. § 636(b)(1), you have 14 days after being served with the attached report to file written objections to the proposed findings of fact, conclusions of law, and recommendations set forth therein. Failure to file written objections to the proposed findings, conclusions, and recommendations within 14 days after being served will bar you, except upon grounds of plain error, from attacking on appeal the unobjected-to proposed factual findings and legal conclusions accepted by the District Court.

ABSOLUTELY NO EXTENSION OF TIME SHALL BE GRANTED TO FILE WRITTEN OBJECTIONS TO THE MAGISTRATE JUDGE’S REPORT.

Signed in Baton Rouge, Louisiana, on March 6, 2026.

S

SCOTT D. JOHNSON UNITED STATES MAGISTRATE JUDGE UNITED STATES DISTRICT COURT

REPORT AND RECOMMENDATION Plaintiff Tyke Fontenot brought this action under 42 U.S.C. § 405(g) for judicial review of the final decision of the Commissioner of the Social Security Administration, terminating his disability insurance benefits.1 Plaintiff has filed a Brief in Support of Appeal (R. Doc. 13), and the Commissioner has filed a Memorandum in Opposition (R. Doc. 14). Plaintiff filed a Reply Memorandum in Support of Appeal (R. Doc. 15). Based on the applicable standard of review under 42 U.S.C. § 405(g), substantial evidence supports the Commissioner’s decision, and the Administrative Law Judge applied the correct legal standards. Accordingly, it is recommended that the Commissioner’s decision be affirmed. I. PROCEDURAL HISTORY On January 14, 2020, Plaintiff filed an application for DIB, alleging disability beginning on August 1, 2019.2 In a determination dated March 4, 2020, Plaintiff was found disabled beginning on August 1, 2019.3 This is the most recent favorable medical decision and is known as the “comparison point decision” or CPD.4 On February 8, 2022, Plaintiff received a Notice of

1 R. Doc. 1 at 1. 2 R. Doc. 8-6 at 2. 3 R. Doc. 8-4 at 2. 4 R. Doc. 8-3 at 16. Disability Cessation, informing him that he was no longer disabled as of February 3, 2022.5 This determination was upheld upon reconsideration after a disability hearing by a state agency Disability Hearing Officer.6 Thereafter, Plaintiff filed a written request for a hearing before an Administrative Law Judge.7 Plaintiff appeared by telephone and testified at a hearing held on March 5, 2024.8 Plaintiff’s main representative was Christina Crotwell, a non-attorney

representative with attorney Loyd Thomas Bourgeois, Jr’s office.9 Christi Lamandre McCaffery, an impartial vocational expert, also appeared and testified by telephone at the hearing.10 After reviewing all of the evidence of record, the ALJ found that Plaintiff’s disability did indeed end on February 3, 2022, and that Plaintiff had not become disabled again since that date.11 Plaintiff sought review of that decision by the Appeals Counsel.12 On September 18, 2024, the Appeals Counsel denied Plaintiff’s request for review.13 On November 1, 2024, Plaintiff timely filed his Complaint with this Court.14 Accordingly, Plaintiff exhausted his administrative remedies before filing this action for judicial review, and the Appeals Council’s decision is the Commissioner’s final decision for purposes of judicial review.15

5 R. Doc. 8-5 at 3. 6 R. Doc. 8-5 at 35. 7 R. Doc. 8-5 at 52. 8 R. Doc. 8-3 at 46. 9 R. Doc. 803 at 50; R. Doc. 8-5 at 112. 10 R. Doc. 8-3 at 47. 11 R. Doc. 8-4 at 46. 12 R. Doc. 8-5 at 141. 13 R. Doc. 8-3 at 2. 14 R. Doc. 1. 15 See 20 C.F.R. § 404.981 (“The Appeals Council may deny a party’s request for review or it may decide to review a case and make a decision. The Appeals Council’s decision, or the decision of the administrative law judge if the request for review is denied, is binding unless you or another party file an action in Federal district court, or the decision is revised. You may file an action in a Federal district court within 60 days after the date you receive notice of the Appeals Council’s action.”). II. STANDARD OF REVIEW The function of a district court on judicial review is limited to determining whether there is “substantial evidence” in the record, as a whole, to support the final decision of the Commissioner as trier of fact, and whether the Commissioner applied the appropriate legal standards to evaluate the evidence. See 42 U.S.C. § 405(g); Brown v. Apfel, 192 F.3d 492, 496 (5th

Cir. 1999); Martinez v. Chater, 64 F.3d 172, 173 (5th Cir. 1995); Carriere v. Sullivan, 944 F.2d 243, 245 (5th Cir. 1991). If the Commissioner's findings are supported by substantial evidence, this Court must affirm them. Martinez, 64 F.3d at 173. “Substantial evidence” is that which is relevant and sufficient for a reasonable mind to accept as adequate to support a conclusion. Richardson v. Perales, 402 U.S. 389, 401(1971); Masterson v. Barnhart, 309 F.3d 267, 272 (5th Cir. 2002). It is more than a scintilla but may be less than a preponderance. Spellman v. Shalala, 1 F.3d 357, 360 (5th Cir. 1993). A finding of no substantial evidence is appropriate only if no credible evidentiary choices or medical findings exist to support the Commissioner's decision. See Boyd v. Apfel, 239 F.3d 698, 704 (5th Cir. 2002).

A district court may not try the issues de novo, re-weigh the evidence, or substitute its own judgment for that of the Commissioner. Carey v. Apfel, 230 F.3d 131, 135 (5th Cir. 2000); Ripley v. Chater, 67 F.3d 552, 555 (5th Cir. 1995); Spellman, 1 F.3d at 360. The Commissioner is entitled to make any finding that is supported by substantial evidence, regardless of whether other conclusions are also permissible. See Arkansas v. Oklahoma, 503 U.S. 91, 112-13 (1992). Conflicts in the evidence are for the Commissioner to resolve, not the courts. Carey, 230 F.3d at 135. Any of the Commissioner's findings of fact that are supported by substantial evidence are conclusive. Ripley, 67 F.3d at 555. Despite this Court's limited function on review, the Court must scrutinize the record in its entirety to determine the reasonableness of the decision reached and whether substantial evidence exists to support it. Anthony v.

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Related

Brown v. Apfel
192 F.3d 492 (Fifth Circuit, 1999)
Newton v. Apfel
209 F.3d 448 (Fifth Circuit, 2000)
Harris v. Apfel
209 F.3d 413 (Fifth Circuit, 2000)
Carey v. Apfel
230 F.3d 131 (Fifth Circuit, 2000)
Boyd v. Apfel
239 F.3d 698 (Fifth Circuit, 2001)
Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Arkansas v. Oklahoma
503 U.S. 91 (Supreme Court, 1992)

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Tyke Fontenot v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tyke-fontenot-v-commissioner-of-social-security-lamd-2026.