Wolfe v. Kijakazi

CourtDistrict Court, S.D. Texas
DecidedFebruary 24, 2025
Docket4:23-cv-04330
StatusUnknown

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

Bluebook
Wolfe v. Kijakazi, (S.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT February 24, 2025 SOUTHERN DISTRICT OF TEXAS Nathan Ochsner, Clerk HOUSTON DIVISION § Karen W., § § Plaintiff, § § Civil Action No. 4:23-cv-04330 v. § § Martin O’Malley,1 § Commissioner of Social Security, § § Defendant. § §

MEMORANDUM AND RECOMMENDATION This appeal from an administrative ruling denying social security benefits was referred to the undersigned judge. Dkt. 7, 13. After carefully considering the parties’ briefs, Dkt. 8, 11, 12, the record, Dkt. 15, and the applicable law, it is recommended that Plaintiff Karen W.’s motion for remand (Dkt. 8) be denied, and that the decision of the Commissioner of Social Security be affirmed. Background Plaintiff filed an application for disability insurance benefits on July 12, 2021. R.10, 325-26. In her application, Plaintiff asserted that she became

1 The Court is aware that O’Malley resigned, and Leland Dudek is the new Acting Commissioner of Social Security. But no request to substitute Dudek for O’Malley has been made. unable to work on March 8, 2020, due to a disabling condition. R.325. As alleged impairments, Plaintiff listed diabetes, gastro-esophageal reflux disease

(“GERD”), nerve pain, osteoarthritis, post-traumatic stress disorder (“PTSD”), spinal stenosis, and headaches. R.175. After her application was denied initially, R.190, 202, 215, and upon reconsideration, R.191, 223, 233, Plaintiff sought and received a hearing before

an administrative law judge (“ALJ”), R.281, 153-74. Plaintiff and a vocational expert (“VE”), Teresa Rogers, testified at the hearing. See R.157-70 (Plaintiff’s testimony); R.170-74 (VE’s testimony). After the hearing, the ALJ issued an opinion concluding that Plaintiff did not qualify as disabled. See R.11, 20-21.

In considering the medical record, the ALJ found that Plaintiff had the following severe impairments: degenerative disc disease of the cervical and lumbar spine; diabetes mellitus; GERD; osteoarthritis of the hips; PTSD; anxiety; and spinal stenosis. R.12. The ALJ then found that Plaintiff does not

have an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments in 20 C.F.R. Part 404, Subpart B, Appendix 1. R.13. This finding was based on the ALJ’s analysis of Plaintiff’s physical and mental impairments. R.13-15.

Given her limitations, the ALJ formulated Plaintiff’s residual functional capacity (“RFC”), finding that she can perform light work as defined in 20 C.F.R. 404.1567(b) except the claimant can stand and/or walk 6 hours in an 8-hour workday; she can sit 6 hours in an 8-hour workday, she can lift and/or carry 10 pounds frequently and 20 pounds occasionally; she can never climb ropes, ladders, or scaffolds; she can frequently climb ramps and stairs; she can occasionally stoop, crouch, kneel, and crawl; she can frequently perform reaching with the bilateral upper extremities; she can perform detailed but not complex instructions and tasks; she can frequently interact with coworkers and the public; and she can maintain adequate concentration, persistence, and pace to remain on-task for all work except assembly line and production- paced work tasks.

R.15. The ALJ created the RFC after evaluating Plaintiff’s asserted symptoms in light of the objective medical evidence and other evidence. R.15-18. The ALJ determined that, with this RFC, Plaintiff can perform her past relevant work as a sales clerk. R.19. The ALJ also found other jobs existing in significant numbers in the national economy that Plaintiff can perform, namely positions as a marker, a garment sorter, and an office helper. R.19-20. Plaintiff unsuccessfully appealed the ALJ’s decision to the Social Security Administration Appeals Council, which rendered the decision ripe for this Court’s review. See R.1-3; 42 U.S.C. § 405(g); Sims v. Apfel, 530 U.S. 103, 106-07 (2000) (“[Social Security Administration] regulations provide that, if ... the [Appeals] Council denies the request for review, the ALJ’s opinion becomes the final decision.”). Legal standard A reviewing court assesses the Commissioner’s denial of social security

benefits “only to ascertain whether (1) the final decision is supported by substantial evidence and (2) whether the Commissioner used the proper legal standards to evaluate the evidence.” Whitehead v. Colvin, 820 F.3d 776, 779 (5th Cir. 2016) (per curiam) (quotation omitted). “Substantial evidence is ‘such

relevant evidence as a reasonable mind might accept to support a conclusion.’” Greenspan v. Shalala, 38 F.3d 232, 236 (5th Cir. 1994) (quoting Richardson v. Perales, 402 U.S. 389, 401 (1971)). It is “more than a scintilla, but it need not be a preponderance.” Taylor v. Astrue, 706 F.3d 600, 602 (5th Cir. 2012)

(quoting Leggett v. Chater, 67 F.3d 558, 564 (5th Cir. 1995)). When conducting its review, the Court cannot reweigh the evidence or substitute its judgment for the Commissioner’s. Brown v. Apfel, 192 F.3d 492, 496 (5th Cir. 1999). “Conflicts of evidence are for the Commissioner, not the

courts, to resolve.” Perez v. Barnhart, 415 F.3d 457, 461 (5th Cir. 2005). But judicial review must not be “so obsequious as to be meaningless.” Brown, 192 F.3d at 496 (quotation omitted). The court must scrutinize the record as a whole, taking into account whatever fairly detracts from the weight of evidence

supporting the Commissioner’s findings. Singletary v. Bowen, 798 F.2d 818, 823 (5th Cir. 1986). Analysis I. Legal Framework

“The Commissioner uses a sequential, five-step approach to determine whether a claimant is ... disabled: (1) whether the claimant is presently performing substantial gainful activity; (2) whether the claimant has a severe impairment; (3) whether the impairment meets or equals a listed impairment;

(4) whether the impairment prevents the claimant from doing past relevant work; and (5) whether the impairment prevents the claimant from performing any other substantial gainful activity.” Morgan v. Colvin, 803 F.3d 773, 776 (5th Cir. 2015) (citing 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4)) (footnote

omitted). Before moving from step three to four, the ALJ determines the claimant’s RFC, which is used to evaluate steps four and five. See id. at 776 n.2 (quoting § 416.1520(a)(4)). “Under this five-step approach, if the Commissioner determines at a

prior step that the applicant is or is not disabled, the evaluation process stops ....” Id. at 776 (citing § 416.1520(a)(4)). The claimant bears the burden of proof at the first four steps. Kneeland v.

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