Walker v. Commissioner, Social Security Administration

CourtDistrict Court, N.D. Texas
DecidedApril 7, 2025
Docket4:24-cv-00402
StatusUnknown

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

Bluebook
Walker v. Commissioner, Social Security Administration, (N.D. Tex. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF TEXAS FORT WORTH DIVISION

RICHARD DAVID WALKER, § Plaintiff, § § V. § CIVIL ACTION NO. 4:24-CV-402-BJ § COMMISSIONER, SOCIAL § SECURITY ADMINISTRATION § Defendant. §

MEMORANDUM OPINION AND ORDER Plaintiff Richard Walker (“Walker”) seeks judicial review of a final adverse decision of the Commissioner of Social Security pursuant to 42 U.S.C. § 405(g). Because the parties have consented to proceed before a magistrate judge, the undersigned has full authority under 28 U.S.C. § 636(c) to consider this appeal, including issuing a final judgment. For reasons stated herein, the decision of the Administrative Law Judge (“ALJ”) is REVERSED and REMANDED. I. STATEMENT OF THE CASE Walker filed this action pursuant to Sections 405(g) and 421(d) of Title 42 of the United States Code for judicial review of a final decision of the Commissioner of Social Security denying his claim for disability insurance benefits (“DIB”) under Title II of the Social Security Act (“SSA”). Walker protectively applied for DIB on August 16, 2022, alleging he became disabled on March 30, 2019. (Transcript (“Tr.”) at 29; see Tr. at 253–56.) After his application for benefits was denied initially and on reconsideration, Walker requested a hearing before an ALJ. (Tr. at 29; see Tr. at 157–72, 181–84.) On August 9, 2023, the ALJ held a hearing by telephone. (Tr. at 29; see Tr. at 131–56, 226.) On November 27, 2023, the ALJ issued an unfavorable opinion. (Tr. at 26–47.) Walker then filed a request for review with the Appeals Council. (Tr. at 251–52.) On March 8, 2024, the Appeals Council denied Walker’s request for review, leaving the ALJ’s, November 27, 2023, decision as the final decision of the Commissioner in Walker’s case. (Tr. at 1–4.) Walker subsequently filed this civil action seeking review of the ALJ’s decision. II. STANDARD OF REVIEW Disability insurance is governed by Title II, 42 U.S.C. § 421 et seq., of the SSA and

numerous regulatory provisions. See 20 C.F.R. pt. 404. The SSA defines a “disability” as a “medically determinable physical or mental impairment” lasting at least twelve months that prevents the claimant from engaging in substantial gainful activity. See 42 U.S.C. §§ 423(d), 1382c(a)(3)(A); McQueen v. Apfel, 168 F.3d 152, 154 (5th Cir. 1999). To determine whether a claimant is disabled, and thus entitled to disability benefits, the Commissioner utilizes a sequential, five-step approach. See 20 C.F.R. § 404.1520(a)(4). At the first step, the Commissioner determines whether the claimant is engaged in any substantial gainful activity.1 See id. § 404.1520(a)(4)(i). At the second step, the Commissioner determines whether the claimant has an impairment or combination of impairments that are severe. Id. § 1520(a)(4)(ii). At the third step, the Commissioner reviews whether the impairment or combination of impairments meets or equals

an impairment listed in the Listing of Impairments (“Listing”). See 20 C.F.R. Pt. 404 Subpt. P, App. 1; 20 C.F.R. § 404.1520(a)(4)(iii), (d). If the impairment of combination of impairments meets or equals an impairment in the Listing, then a disability finding is proper. See 20 C.F.R. § 404.1520(a)(4)(iii), (d). Before moving from the third to the fourth step of the inquiry, the Commissioner assesses the claimant’s residual functional capacity (“RFC”) to determine the most the claimant is able to do notwithstanding his physical and mental limitations. See 20 C.F.R. § 404.1520(a)(4), (e). The claimant’s RFC is used at both the fourth and fifth steps of the five-step analysis. See 20 C.F.R. § 404.1520(a)(4). At step four, the claimant’s RFC is used to determine if

1“Substantial gainful activity” is defined as work activity involving the use of significant and productive physical or mental abilities for pay or profit. See 20 C.F.R. § 404.1510. the claimant can still do his past relevant work. See 20 C.F.R. § 404.1520(a)(4)(iv), (f). At step five, the claimant’s RFC, age, education, and past work experiences are used to determine whether the claimant can adjust to other types of work. See 20 C.F.R. § 404.1520(a)(4)(v), (g); Crowley v. Apfel, 197 F.3d 194, 197–98 (5th Cir. 1999).

At steps one through four, the burden of proof rests upon the claimant to show he is disabled. Crowley, 197 F.3d at 198. If the claimant satisfies this responsibility, the burden shifts to the Commissioner to show that there is other gainful employment the claimant is capable of performing despite his existing impairments. Id. If the Commissioner meets his burden, it is up to the claimant to rebut the Commissioner’s findings. See Carey v. Apfel, 230 F.3d 131, 135 (5th Cir. 2000). In cases such as this one, where substance abuse is involved, SSR 13-2p outlines a detailed six-step process for evaluating the impact of substance abuse on a disability claim that is in addition to the above-listed five-step sequential evaluation process. See SSR 13-2p, 2013 WL 621536, at *5–6 (S.S.A. Feb. 20, 2013). Where there is “‘evidence from medical sources . . . establishing that

[drug/alcohol abuse (“DAA”)] is a medically determinable impairment (MDI),’ a determination must first be made as to whether a claimant is disabled considering all MDIs (including DAA).” See Ellis v. Saul, No. 20-329-BAJ-EWD, 2021 WL 4484561, at *5 (M.D. La. Sept. 7, 2021), report and recommendation adopted, 2021 WL 4483062 (M.D. La. Sept. 29, 2021) (citing SSR 13-2p, 2013 WL 621536, at *4). If so, the Commissioner “must then determine whether the claimant would continue to be disabled if he or she stopped using drugs or alcohol; that is . . . [the Commissioner] will determine whether DAA is ‘material’ to the finding that the claimant is disabled.” See SSR 13-2p, 2013 WL 621536, at *2. In other words, the ALJ, in essence, follows the above-listed, five-step sequential evaluation process considering a claimant’s substance abuse. Id. Then the ALJ follows the same five-step, sequential process, except, this time, without considering claimant’s substance abuse. Id. Where the claimant is found disabled with the substance abuse but not found disabled without substance abuse, then the claimant’s substance abuse disorder is deemed to be a material factor to the determination of disability and the claimant

is not disabled. See 42 U.S.C. § 423(d)(2); Ellis, 2021 WL 4484561, at *5.

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Walker v. Commissioner, Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/walker-v-commissioner-social-security-administration-txnd-2025.