Williamson v. Commissioner of Social Security Administration

CourtDistrict Court, W.D. Oklahoma
DecidedMay 19, 2025
Docket5:24-cv-01302
StatusUnknown

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

Bluebook
Williamson v. Commissioner of Social Security Administration, (W.D. Okla. 2025).

Opinion

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

LINDA W., ) ) Plaintiff, ) ) v. ) Case No. CIV-24-1302-SM ) Frank Bisignano, ) COMMISSIONER ) OF SOCIAL SECURITY,1 ) ) Defendant. )

MEMORANDUM OPINION AND ORDER

Linda W.2 (Plaintiff), seeks judicial review of the Commissioner of Social Security’s final decision that she was not “disabled” under the Social Security Act. See 42 U.S.C. § 405(g). The parties have consented to proceed before the undersigned for disposition. Docs. 6 & 7; see 28 U.S.C. § 636(c).3 Plaintiff asks this Court to reverse the Commissioner’s decision and remand the case for further proceedings, arguing that the Administrative Law

1 Frank Bisignano became the Commissioner of the Social Security Administration on May 7, 2025. So the Court replaces Leland Dudek as Defendant with Frank Bisignano. See Fed. R. Civ. P. 25(d).

2 Plaintiff is referred to by first name and last initial only to protect Plaintiff’s privacy because of the sensitive nature of medical and personal information disclosed in Social Security cases.

3 Citations to the parties’ pleadings and attached exhibits will refer to this Court’s CM/ECF pagination. Citations to the administrative record (AR) will refer to its original pagination. Judge (ALJ) failed to properly consider the consultative examiner’s findings. Doc. 8, at 3-10.

After careful review of the AR, the parties’ briefs, and the relevant authority, the Court affirms the Commissioner’s decision. See 42 U.S.C. § 405(g). I. Administrative determination.

A. Disability standard. Plaintiff protectively filed a Title II (42 U.S.C. § 401, et seq.) application for disabled widow’s benefits and a month later, filed a Title XVI (42 U.S.C. § 1381, et seq.) application for supplemental security income benefits. AR 241,

245. Her amended alleged onset date of disability is June 26, 2022 (also the date the disabled worker died). Id. at 18-19. The Social Security 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 [twelve] months.” 42 U.S.C. § 423(d)(1)(A). “This twelve-month duration requirement applies to the claimant’s inability to engage in any substantial

gainful activity, and not just [the claimant’s] underlying impairment.” Lax v.

2 Astrue, 489 F.3d 1080, 1084 (10th Cir. 2007) (citing Barnhart v. Walton, 535 U.S. 212, 218-19 (2002)).

B. Burden of proof. Plaintiff “bears the burden of establishing a disability” and of “ma[king] a prima facie showing that she can no longer engage in h[er] prior work activity.” Turner v. Heckler, 754 F.2d 326, 328 (10th Cir. 1985). If Plaintiff

makes that prima facie showing, the burden of proof then shifts to the Commissioner to show Plaintiff “retains the capacity to perform” a different type of work and that such a “specific type of job exists in the national economy.” Id.

The parties do not dispute that Plaintiff is the widow of a deceased worker, has attained the age of 50, and is unmarried (and no exception for 20 C.F.R. § 404.335(e) applies). AR 20. For disabled widow’s benefits, her prescribed period began on June 26, 2022, the date the wage earner died. Id.

at 19. She must establish her disability began on or before June 30, 2029 to be entitled to disabled widow’s benefits. Id.

3 C. Relevant findings. 1. ALJ’s findings.

The ALJ assigned to Plaintiff’s case applied the standard regulatory analysis to decide whether Plaintiff was disabled during the relevant timeframe. AR 18-34; see also Wall v. Astrue, 561 F.3d 1048, 1052 (10th Cir. 2009) (describing the five-step process). The ALJ found Plaintiff:

(1) had not engaged in substantial gainful activity since June 26, 2022, the amended alleged onset date;

(2) has the severe medically determinable impairments of abnormality of a major joint (osteoarthritis of the right knee); obesity; Type 2 diabetes mellitus with diabetic chronic kidney disease; renal dysfunction; acute kidney failure; chronic kidney disease stage 3b; and osteoarthritis;

(3) had no impairment or combination of impairments that met or medically equaled the severity of a listed impairment;

(4) had the residual functional capacity4 (RFC) to perform the full range of light exertion work defined in 20 C.F.R. §§ 404.1567(b), 416.967(b);

(5) can adjust to other work and that a finding about Plaintiff’s capacity to perform any past relevant work has not been made;

(6) the potentially applicable medical-vocational guidelines direct a finding of not disabled given Plaintiff’s age (45), education (at least a high school education), and RFC;

4 “[R]esidual functional capacity is the most [a claimant] can still do despite [a claimant’s] limitations.” 20 C.F.R. §§ 404.1545(a)(1); 416.945(a).

4 (6) had not been under a disability since June 26, 2022 through May 10, 2024.

AR 20-34. 2. Appeals Council’s findings. The Social Security Administration’s Appeals Council denied Plaintiff’s request for review, see id. at 1-3, “making the ALJ’s decision the Commissioner’s final decision for [judicial] review.” Krauser v. Astrue, 638 F.3d 1324, 1327 (10th Cir. 2011); see 20 C.F.R. §§ 404.981, 416.1481. II. Judicial review of the Commissioner’s decision. A. Review standard.

The Court reviews the Commissioner’s final decision to determine “whether substantial evidence supports the factual findings and whether the ALJ applied the correct legal standards.” Allman v. Colvin, 813 F.3d 1326, 1330 (10th Cir. 2016) (internal citation omitted). “An agency decision that

either applies an incorrect legal standard or is unsupported by substantial evidence is subject to reversal.” Staheli v. Comm’r, SSA, 84 F.4th 901, 905 (10th Cir. 2023). “Substantial evidence is such relevant evidence as a reasonable mind

might accept as adequate to support a conclusion.” Id. (quoting Wilson v.

5 Astrue, 602 F.3d 1136, 1140 (10th Cir. 2010)); see also Lax, 489 F.3d at 1084 (defining substantial evidence as “more than a scintilla, but less than a

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