Wallis v. Commissioner of Social Security Administration

CourtDistrict Court, D. Arizona
DecidedJuly 7, 2022
Docket3:21-cv-08132
StatusUnknown

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

Bluebook
Wallis v. Commissioner of Social Security Administration, (D. Ariz. 2022).

Opinion

1 WO 2 3 4 5 6 IN THE UNITED STATES DISTRICT COURT 7 FOR THE DISTRICT OF ARIZONA

9 Jonathan Wallis, No. CV-21-08132-PHX-JAT

10 Plaintiff, ORDER

11 v.

12 Commissioner of Social Security Administration, 13 Defendant. 14 15 Pending before the Court is Plaintiff Jonathan Wallis’s appeal from the 16 Commissioner of the Social Security Administration’s (“SSA”) denial of social security 17 disability benefits. (Doc. 16). The appeal is fully briefed (Doc. 16, Doc. 18, Doc. 19), and 18 the Court now rules. 19 I. BACKGROUND 20 The issues presented in this appeal are whether substantial evidence supports the 21 Administrative Law Judge’s (“ALJ”) determination that Plaintiff was not disabled from 22 April 1, 2018 to December 22, 2020 and whether the ALJ committed legal error in his 23 analysis. (Doc. 16 at 4; Doc. 15-3 at 15). 24 a. Factual Overview 25 Plaintiff was 37 years old on the alleged disability onset date. (Doc. 15-3 at 21). He 26 has a high school education and past relevant work experience as a heavy equipment 27 operator and fast-food worker. (Id.) Plaintiff filed his disability insurance benefits (DIB) 28 application on November 5, 2018, alleging disabilities beginning on April 1, 2018, 1 including obesity, multilevel degenerative disc disease, left ankle impingement syndrome, 2 carpal tunnel syndrome, and hypertension. (Id. at 16). Plaintiff also filed an application for 3 supplemental social security income (SSI) on October 15, 2018. (Id. at 14). An ALJ denied 4 Plaintiff’s claim on December 22, 2020, after a telephonic hearing. (Id. at 14–15). The SSA 5 Appeals Council denied a request for review of that decision and adopted the ALJ’s 6 decision as the agency’s final decision. (Id. at 2). 7 b. The SSA’s Five-Step Evaluation Process 8 To qualify for social security benefits, a claimant must show he “is under a 9 disability.” 42 U.S.C. § 423(a)(1)(E). A claimant is disabled if he suffers from a medically 10 determinable physical or mental impairment that prevents him from engaging “in any 11 substantial gainful activity.” Id. § 423(d)(1)–(2). The SSA has created a five-step process 12 for an ALJ to determine whether the claimant is disabled. See 20 C.F.R. § 404.1520(a)(1).1 13 Each step is potentially dispositive. See id. § 404.1520(a)(4). 14 At the first step, the ALJ determines whether the claimant is “doing substantial 15 gainful activity.” Id. § 404.1520(a)(4)(i). If so, the claimant is not disabled. Id. Substantial 16 gainful activity is work activity that is both “substantial,” involving “significant physical 17 or mental activities,” and “gainful,” done “for pay or profit.” Id. § 404.1572(a)–(b). 18 At the second step, the ALJ considers the medical severity of the claimant’s 19 impairments. Id. § 404.1520(a)(4)(ii). If the claimant does not have “a severe medically 20 determinable physical or mental impairment,” the claimant is not disabled. Id. A “severe 21 impairment” is one which “significantly limits [the claimant’s] physical or mental ability 22 to do basic work activities.” Id. § 404.1520(c). Basic work activities are “the abilities and 23 aptitudes necessary to do most jobs.” Id. § 404.1522(b). 24 At the third step, the ALJ determines whether the claimant’s impairment or 25 combination of impairments “meets or equals” an impairment listed in Appendix 1 to 26 Subpart P of 20 C.F.R. Part 404. Id. § 404.1520(a)(4)(iii). If so, the claimant is disabled. 27 1 The Court notes that the relevant regulations for both DIB and SSI applications are 28 virtually identical. Thus, the Court will only cite to DIB regulations found in 20 C.F.R. Part 404. For reference, parallel SSI regulations are listed in 20 C.F.R. Part 416. 1 Id. If not, before proceeding to step four, the ALJ must assess the claimant’s “residual 2 functional capacity” (“RFC”). Id. § 404.1520(a)(4). The RFC represents the most a 3 claimant “can still do despite [his] limitations.” Id. § 404.1545(a)(1). In assessing the 4 claimant’s RFC, the ALJ will consider the claimant’s “impairment(s), and any related 5 symptoms, such as pain, [that] may cause physical and mental limitations that affect what 6 [the claimant] can do in a work setting.” Id. 7 At the fourth step, the ALJ uses the RFC to determine whether the claimant can still 8 perform his “past relevant work.” Id. § 404.1520(a)(4)(iv). The ALJ compares the 9 claimant’s RFC with the physical and mental demands of the claimant’s past relevant work. 10 Id. § 404.1520(f). If the claimant can still perform his past relevant work, the ALJ will find 11 that the claimant is not disabled. Id. § 404.1520(a)(4)(iv). 12 At the fifth and final step, the ALJ determines whether—considering the claimant’s 13 RFC, age, education, and work experience—he “can make an adjustment to other work.” 14 Id. § 404.1520(a)(4)(v). If the ALJ finds that the claimant can make an adjustment to other 15 work, then the claimant is not disabled. Id. If the ALJ finds that the claimant cannot make 16 an adjustment to other work, then the claimant is disabled. Id. 17 c. The ALJ’s Application of the Factors 18 Here, at the first step, the ALJ concluded that Plaintiff had not engaged in substantial 19 gainful activity since the alleged onset date of his disability. (Doc. 15-3 at 16). 20 At the second step, the ALJ determined that Plaintiff’s obesity, multilevel 21 degenerative disc disease, and left ankle impingement syndrome constituted severe 22 impairments under 20 C.F.R. § 404.1520(c). (Id.) The ALJ also determined that the rest of 23 Plaintiff’s alleged impairments were non-severe. (Id. at 17). 24 At the third step, the ALJ determined that Plaintiff’s impairments did not meet or 25 equal the severity of one of the impairments listed in 20 C.F.R. Part 404, Subpart P, 26 Appendix 1. (Id. at 17–18). After evaluating Plaintiff’s RFC, the ALJ concluded that 27 Plaintiff could perform light work as defined in 20 C.F.R. § 404.1567(b), “except that 28 [Plaintiff] can lift and/or carry 20 pounds occasionally and 10 pounds frequently.” (Id. at 1 18) The ALJ also found that: [Plaintiff] can stand and/or walk in combination up to 2 hours 2 daily, as well as sit for 6 hours in an 8-hour workday. [Plaintiff] 3 may seldom (5% or less often) ambulate on rough or uneven surfaces and may use a handheld assistive device when doing 4 so. [Plaintiff] can occasionally climb ramps and stairs, but 5 should never climb ladders, ropes, or scaffolds. [Plaintiff] can occasionally balance, stoop, kneel, crouch, and crawl. 6 [Plaintiff] may not operate foot controls with the left lower 7 extremity. [Plaintiff] should avoid concentrated exposure to vibration, extreme cold temperatures/weather, as well as to 8 hazards (e.g., dangerous machinery, unprotected heights). 9 [Plaintiff] may change position briefly between sitting and standing as frequently as every half hour without loss of 10 productivity. 11 (Id.) 12 At the fourth step, the ALJ concluded that Plaintiff is unable to perform any past 13 relevant work. (Id. at 21).

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Bluebook (online)
Wallis v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wallis-v-commissioner-of-social-security-administration-azd-2022.