Valero v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedAugust 21, 2023
Docket6:22-cv-00154
StatusUnknown

This text of Valero v. Social Security Administration (Valero 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
Valero v. Social Security Administration, (E.D. Okla. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF OKLAHOMA

LIA E. VALERO, ) ) Plaintiff, ) ) v. ) Case No. 22-cv-154-DES ) KILOLO KIJAKAZI, ) Acting Commissioner of the Social ) Security Administration, ) ) Defendant. ) OPINION AND ORDER Pursuant to 42 U.S.C. § 405(g), Plaintiff LIA E. VALERO (“Claimant”) seeks judicial review of a final decision by the Commissioner of the Social Security Administration (“Commissioner”) denying her claim for supplemental security income benefits under Title XVI of the Social Security Act (the “Act”). For the reasons explained below, the Court AFFIRMS the Commissioner’s decision denying benefits. I. Statutory Framework and Standard of Review The Act defines “disability” as the “inability 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. § 423(d)(1)(A). To be deemed disabled under the Act, a claimant’s impairment(s) must be “of such severity that [s]he is not only unable to do h[er] previous work but cannot, considering h[er] age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy.” 42 U.S.C. § 423(d)(2)(A). Social security regulations implement a five-step sequential process to evaluate a disability claim. 20 C.F.R. § 416.920(a)(4). This process requires the Commissioner to consider: (1) whether the claimant is engaged in substantial gainful activity; (2) whether the claimant suffers from a medically determinable severe impairment(s); (3) whether such impairment meets or medically equals a listed impairment set forth in 20 C.F.R. pt. 404, subpt. P, app. 1; (4) whether the claimant can perform her past relevant work considering the Commissioner’s assessment of the claimant’s residual functional capacity (“RFC”); and (5) whether the claimant can perform

other work considering the RFC and certain vocational factors. 20 C.F.R. § 416.920(a)(4)(i)-(v). The claimant bears the burden of proof through step four, but the burden shifts to the Commissioner at step five. Lax v. Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007). If it is determined, at any step of the process, that the claimant is or is not disabled, evaluation under a subsequent step is not necessary. Williams v. Bowen, 844 F.2d 748, 750 (10th Cir. 1988). A district court’s review of the Commissioner’s final decision is governed by 42 U.S.C. § 405(g). The scope of judicial review under § 405(g) is limited to determining whether the Commissioner applied the correct legal standards and whether the Commissioner’s factual findings are supported by substantial evidence. See Noreja v. Soc. Sec. Comm’r, 952 F.3d 1172, 1177 (10th

Cir. 2020). Substantial evidence is more than a scintilla but means only “‘such evidence as a reasonable mind might accept as adequate to support a conclusion.’” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938). In conducting its review, the Court “may neither reweigh the evidence nor substitute [its] judgment for that of the agency.” Noreja, 952 F.3d at 1178 (quotation omitted). Rather, the Court must “meticulously examine the record as a whole, including anything that may undercut or detract from the ALJ’s findings in order to determine if the substantiality test has been met.” Flaherty v. Astrue, 515 F.3d 1067, 1070 (10th Cir. 2007) (quotation omitted). II. Claimant’s Background and Procedural History On March 18, 2020, Claimant protectively applied for supplemental security income benefits under Title XVI of the Act. (R. 12, 183-88). Claimant alleges she has been unable to work since an amended alleged onset date of August 23, 2020, due to chronic obstructive pulmonary disorder (“COPD”), arthritis, and bone spurs. (R. 13, 236, 298). Claimant was 56

years old on the date of the ALJ’s decision. (R. 23, 33). She has a high school education and past work as a fast-food services manager, sandwich maker, customer complaint clerk, and insurance clerk. (R. 33, 54-55). Claimant’s claim for benefits was denied initially and on reconsideration, and she requested a hearing. (R. 63-94, 116-18). ALJ Edward M. Starr conducted an administrative hearing and issued a decision on September 29, 2021, finding Claimant not disabled. (R. 12-23, 29-61). The Appeals Council denied review on March 23, 2022 (R. 1-6), rendering the Commissioner’s decision final. 20 C.F.R. § 416.1481. Claimant filed this appeal on May 23, 2022. (Docket No. 2).

III. The ALJ’s Decision In his decision, the ALJ found at step one that Claimant had not engaged in substantial gainful activity since her amended onset date of August 23, 2020. (R. 15). At step two, the ALJ found Claimant had severe impairments of disorder of the spine, obesity, and hypertension, but that her trauma-related disorder was nonsevere. (R. 16). At step three, the ALJ found Claimant’s impairments did not meet or equal a listed impairment. (R. 17). Before proceeding to step four, the ALJ determined Plaintiff had the RFC to perform light work as defined in 20 C.F.R. § 416.967(b) with the following non-exertional limitations: [T]he claimant can only occasionally climb, crawl, kneel, stoop, and/or crouch; and the claimant can frequently, but not constantly, reach with her right dominant upper extremity.

(R. 18). Based on the testimony of a vocational expert (“VE”), the ALJ concluded at step four that Claimant could return to her past relevant work as a customer complaint clerk, as she actually performed such occupation and as it is generally performed in the national economy. (R. 23). Accordingly, the ALJ concluded Claimant was not disabled. Id. IV. Issues Presented Claimant asserts the ALJ erred by: (1) failing to consider all her impairments at step two (Docket No. 14 at 4); (2) failing to account for all her impairments and limitations in the RFC (id. at 3-5); and (3) failing to properly evaluate the medical source opinions of Jamie Lyons and the state agency physicians (id. at 5-6). The Court finds no reversible error in the ALJ’s decision. V. Analysis A. ALJ’s Error in Assessing the Severity of Claimant’s Mental Impairments Was Harmless

Plaintiff contends that the ALJ erred at step two by failing to consider her diagnosed depression and anxiety at step two of the sequential evaluation.1 (Docket No. 14 at 4). The ALJ considers the “medical severity” of a claimant’s impairments at step two of the sequential evaluation. 20 C.F.R.

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Bluebook (online)
Valero v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/valero-v-social-security-administration-oked-2023.