Whitten v. Social Security Administration

CourtDistrict Court, E.D. Oklahoma
DecidedMarch 14, 2024
Docket6:22-cv-00275
StatusUnknown

This text of Whitten v. Social Security Administration (Whitten 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
Whitten v. Social Security Administration, (E.D. Okla. 2024).

Opinion

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

DENNIS WHITTEN, ) ) Plaintiff, ) ) v. ) Case No. 22-cv-275-DES ) MARTIN O’MALLEY, 1 ) Commissioner of Social Security, ) ) Defendant. )

OPINION AND ORDER Pursuant to 42 U.S.C. § 405(g), Plaintiff Dennis Whitten (“Claimant”) seeks judicial review of a final decision by the Commissioner of the Social Security Administration (“Commissioner”) denying her claim for disability insurance benefits under Title II of the Social Security Act (the “Act”). For the reasons explained below, the Court REVERSES and REMANDS 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 he is not only unable to do his previous work but cannot, considering his 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).

1 Effective December 20, 2023, Martin O’Malley, Commissioner of Social Security, is substituted as the defendant in this action pursuant to Fed. R. Civ. P. 25(d). No further action is necessary to continue this suit by reason of 42 U.S.C. § 405(g). Social security regulations implement a five-step sequential process to evaluate a disability claim. 20 C.F.R. § 404.1520(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 his 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. § 404.1520(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. 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 July 14, 2020, Claimant protectively applied for disability insurance benefits under Title II of the Act. (R. 14, 200-03). Claimant alleges he has been unable to work since September

24, 2019, due to back problems, degenerative disc disease, a left knee problem, a right shoulder problem, diabetes, bronchitis, asthma, chronic obstructive pulmonary disease (“COPD”), headaches, difficulty hearing, a cataract, neuropathy in his feet, and pain in his back, hip, and leg. (R. 200, 217). Claimant was 66 years old on the date of the ALJ’s decision. (R. 21, 200). He has a college education and past work as a drug and alcohol abuse counselor. (R. 20, 218). Claimant’s claim for benefits was denied initially and on reconsideration, and he requested a hearing. (R. 53-89, 110-11). ALJ Susanne M. Cichanowicz conducted an administrative hearing and issued a decision on March 30, 2022, finding Claimant not disabled. (R. 14-21, 27-51). The Appeals Council denied review on July 25, 2022 (R. 3-8), rendering the Commissioner’s decision

final. 20 C.F.R. § 404.981. Claimant filed this appeal on September 27, 2022. (Docket No. 2). III. The ALJ’s Decision In her decision, the ALJ found Claimant met the insured requirements for Title II purposes through September 30, 2021. (R. 16). The ALJ then found at step one that Claimant had not engaged in substantial gainful activity during the period from his alleged onset date of September 24, 2019, through his date last insured of September 30, 2021. (Id.). At step two, the ALJ found Claimant had the severe impairments of lumbar spine degenerative disc disease status post fusion, cervical spine degenerative disc disease, and left knee arthroplasty, but that his inflammatory polyarthritis, bilateral hand osteoarthritis, right rotator cuff repair, and diabetes mellitus were non- severe. (R. 16-17). 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 less than the full range of light work as defined in 20 C.F.R. § 404.1567(b), as follows: [T]he claimant can lift/carry, push/pull 20 pounds occasionally and 10 pounds frequently; he can stand/walk for 4 hours in an 8-hour workday; he can sit for 6 hours in an 8-hour workday; he can occasionally climb ramps or stairs, but never climb ladders, ropes, or scaffolds; he can occasionally balance, stoop, kneel, crouch and crawl.

(R. 17-18). The ALJ provided a summary of some of the evidence that went into this finding. (R. 18-19).

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Related

Lax v. Astrue
489 F.3d 1080 (Tenth Circuit, 2007)
Wells v. Astrue
727 F.3d 1061 (Tenth Circuit, 2013)
Flaherty v. Astrue
515 F.3d 1067 (Tenth Circuit, 2008)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Noreja v. Commissioner, SSA
952 F.3d 1172 (Tenth Circuit, 2020)

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Bluebook (online)
Whitten v. Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/whitten-v-social-security-administration-oked-2024.