Smith v. Commissioner of Social Security

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IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF TEXAS
AMARILLO DIVISION
STEVEN PATRICK SMITH, 	§
Plaintiff, 	§
§
V. 	§ 	CIVIL ACTION NO. 2:25-CV-137-BJ
§
COMMISSIONER OF SOCIAL SECURITY 	§
Defendant. 	§
MEMORANDUM OPINION AND ORDER
Plaintiff Steven Patrick Smith (“Smith”) 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 AFFIRMED.
I. 	STATEMENT OF THE CASE
Smith filed this action pursuant to Section 405(g) and 1383(c) of Title 42 of the United
States Code for judicial review of a final decision of the Commissioner of Social Security denying
his claims for disability insurance benefits (“DIB”) under Title II and supplemental security
income (“SSI”) under Title XVI of the Social Security Act (“SSA”). 	In March of 2022, Smith
protectively applied for DIB and SSI, alleging his disability began on June 1, 2005. (Transcript
(“Tr.”) 236-47.) He later amended his onset date to April 8, 2010. (Tr. 46.) After his applications
for DIB and SSI were denied both initially and on reconsideration, Smith requested a hearing
before an ALJ. (Tr. 153-54.) On August 12, 2024, the ALJ held a hearing. (Tr. 43.) Thereafter,
on January 6, 2025, the ALJ issued an unfavorable opinion. (Tr. 34.) Smith then filed a request
for review with the Appeals Council. (Tr. 7-10.) On April 21, 2025, the Appeals Council denied
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Smith’s request for review, leaving the ALJ’s January 6, 2025 decision as the final decision of the
Commissioner in Smith’s case. (Tr. 1.) Smith 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. §§ 401-434, and SSI benefits are
governed by Title XVI, 42 U.S.C. §§ 1381-1385, of the SSA. In addition, numerous regulatory
provisions govern disability insurance and SSI benefits. 	See 20 C.F.R. Pt. 404 (disability
insurance); 20 C.F.R. Pt. 416 (SSI). 	Although technically governed by different statutes and
regulations, “[t]he law and regulations governing the determination of disability are the same for
both disability insurance benefits and SSI.” 	Greenspan v. Shalala, 38 F.3d 232, 236 (5th Cir.
1994).
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. 42 U.S.C. § 423(d); McQueen v. Apfel, 168 F.3d 152, 154 (5th Cir. 1999). To determine
whether a claimant is disabled, and thus entitled to disability benefits, a five-step analysis is
employed. See 20 C.F.R. §§ 404.1520, 416.920. First, the claimant must not be presently working
at any substantial gainful activity. 	See id. §§ 404.1520(a)(4)(i), 416.920(a)(4)(i). 	Substantial
gainful activity is defined as work activity involving the use of significant physical or mental
abilities for pay or profit. 20 C.F.R. §§ 404.1572, 416.972. Second, the claimant must have an
impairment or combination of impairments that is severe. See 20 C.F.R. §§ 404.1520(a)(4)(ii), (c),
416.920(a)(4)(ii), (c); see also Stone v. Heckler, 752 F.2d 1099, 1101 (5th Cir. 1985). 	Third,
disability will be found if the impairment, or combination of impairments, meets or equals an
impairment listed in the Listing of Impairments (“Listing”), 20 C.F.R. Pt. 404 Subpt. P, App. 1.
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See 20 C.F.R. §§ 404.1520(a)(iii), (d), 416.920(a)(iii), (d).1 Fourth, if disability cannot be found
based on the claimant’s medical status alone, the impairment or impairments must prevent the
claimant from returning to his past relevant work. 	20 C.F.R. §§ 404.l520(a)(4)(iv), (f),
416.920(a)(4)(iv), (f). And fifth, the impairment must prevent the claimant from doing any work,
considering the claimant’s residual functional capacity (“RFC”), age, education, and past work
experience. 	Id. §§ 404.l520(a)(4)(v), (g), 416.920(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 she 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 in spite of his existing impairments. 	Id. 	If the Commissioner meets his
burden, it is up to the claimant to then show that she cannot perform the alternate work. See Carey
v. Apfel, 230 F.3d 131, 135 (5th Cir. 2000).
A denial of disability benefits is reviewed only to determine whether the Commissioner
applied the correct legal standards, and whether the decision is supported by substantial evidence
in the record as a whole. Leggett v. Chater, 67 F.3d 558, 564 (5th Cir. 1995); Hollis v. Bowen, 837
F.2d 1378, 1382 (5th Cir. 1988) (per curiam). Substantial evidence is such relevant evidence as a
reasonable mind might accept to support a conclusion. Boyd v. Apfel, 239 F.3d 698, 704 (5th Cir.
2001). 	It is more than a mere scintilla, but less than a preponderance. 	Id. 	A finding of no
substantial evidence is appropriate only if no credible evidentiary choices or medical findings
support the decision. Id. (emphasis added). An ALJ’s decision is not subject to reversal, even if
1 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 her physical
and mental limitations. 20 C.F.R. §§ 404.1520(a)(4), (e), 416.920(a)(4), (e). The claimant’s RFC is used at both the
fourth and fifth steps of the five-step analysis. Id. §§ 404.1520(a)(4), 416.920(a)(4). At Step Four, the claimant’s
RFC is used to determine if the claimant can still do her past relevant work. 	Id. §§ 404.1520(a)(4)(iv),
416.920(a)(4)(iv). At Step Five, the claimant’s RFC is used to determine whether the claimant can adjust to other
types of work. Id. §§ 404.1520(a)(4)(v), 416.920(a)(4)(v).
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there is substantial evidence in the record that would have supported the opposite conclusion, so
long as substantial evidence supports the conclusion that was reached by the ALJ. 	Dollins v.
Astrue, No. 4:08-CV-00503-A, 2009 WL 1542466, at *5 (N.D. Tex. June 2, 2009). 	This Court
may neither reweigh the evidence in the record nor substitute its judgment for the Commissioner’s,
but it will carefully scrutinize the record to determine if substantial evidence is present. Harris v.
Apfel, 209 F.3d 413, 417 (5th Cir. 2000); Hollis, 837 F.2d at 1383.
III. 	ISSUES
In his brief, Smith raises the following issue: Whether the ALJ improperly evaluated State
Agency Medical Consultant Renee McPherson Watson (“SAMC 	Watson”)’s medical opinion.
(Plaintiff’s Brief (“Pl.’s Br.”) at 1.)
IV. 	ALJ DECISION
In her January 6, 2025 decision, the ALJ concluded that Smith was not disabled within the
meaning of the SSA. (Tr. 22.) In making her determination, the ALJ proceeded to follow the five-
step sequential evaluation process set forth above. (Tr. 24-33.) At Step One, the ALJ found that
Smith had not engaged in substantial gainful activity since April 8, 2010, the amended alleged
onset date of Smith’s disability. (Tr. 24.) At Step Two, the ALJ held that Smith had the “severe”
impairment of schizophrenia. (Tr. 24.) At Step Three, the ALJ found that Smith did not have an
impairment or combination of impairments that met or was medically equivalent to the severity of
one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1. 	(Tr. 24, 26.) As to
Smith’s RFC, the ALJ stated:
After careful consideration of the entire record, I find that the claimant has the
residual functional capacity to perform a full range of work at all exertional levels
but with the following non-exertional limitations: the claimant is limited to simple
tasks and instructions; the claimant cannot perform fast or production paced work;
the claimant is limited to occasional changes in the work setting; the claimant must
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have no public contact; the claimant cannot perform joint, team, or tandem tasks;
and the claimant is limited to occasional contact with co-workers and supervisors.
(Tr. 28 (emphasis omitted).) At Step Four, the ALJ stated that Smith had no past relevant work.
(Tr. 32.) Finally, at Step Five, in light of the testimony provided by a vocational expert, the ALJ
found that, “considering the claimant’s age, education, work experience, and residual functional
capacity, the claimant is capable of making a successful adjustment to other work that exists in
significant numbers in the national economy.” (Tr. 32-33.) Accordingly, the ALJ found that Smith
was not disabled, as defined by the SSA from April 8, 2010 through the date of her decision. (Tr.
33.)
V. 	DISCUSSION
In his brief, Smith claims that the ALJ improperly evaluated SAMC Watson’s medical
opinion 	by “not adher[ing] to the specific requirements regarding the discussion 	of the
supportability and consistency factors.” 	(Pl.’s Br. at 8.) 	Smith argues this is reversable error
because the ALJ formulated an RFC that did not accurately reflect all of Smith’s limitations. (Pl.’s
Br. at 11-12.)
A. 	Improper Evaluation of SAMC Watson’s Medical Opinion
The ALJ must “articulate in [her] determination or decision how persuasive [she] find[s]
all of the medical findings in [the claimant’s] case record.” 	20 C.F.R. §§ 404.1520c(b),
416.920c(b). 	Specifically, the ALJ is required to “explain how [she] considered the supportability
and consistency factors for a medical source’s medical opinions.”2 20 C.F.R. §§ 404.1520c(b)(2),
2 Supportability requires the ALJ to evaluate how “relevant the objective medical evidence and supporting
explanations presented by a medical source are to support his or her medical opinion(s),” while consistency requires
the ALJ to evaluate how “consistent a medical opinion(s) . . . is with the evidence from other medical sources and
nonmedical sources in the claim.” 20 C.F.R. §§ 404.1520c(c), 416.920c(c).
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416.920c(b)(2). 	All the ALJ must do is build a “logical bridge” between her persuasiveness
finding and the medical evidence. See Price v. Astrue, 401 F.App’x 985, 986 (5th Cir. 2010).
In her decision, the ALJ considered the disability opinion of SAMC Watson “partially
persuasive” because “[t]his opinion limited the claimant to simple work, which is supported based
on the medical history. However, the remaining limitations listed in this opinion appeared vague
and unsupported based on the normal mental status examination results outlined above (Exhibits
8A and 9A).” (Tr. 31.) The ALJ previously discussed Smith’s medical history which showed that
he exhibited moderate limitations in (1) understanding, remembering, or applying information; (2)
concentrating, persisting, or maintaining pace; and (3) adapting oneself. 	(Tr. 26-27.) Further,
according to the ALJ’s previous analysis of the mental status examination and of the findings of
impartial psychological expert Dr. Trevan Prickett, Smith’s mental impairment “remained stable
and well controlled with treatment.” 	(Tr. 30.) 	The mental status exams appeared “intact with
normal attention/concentration, intact memory, normal mood, and appropriate affect.” (Tr. 30.)
The results “showed the claimant displayed good concentration” and did not indicate that Smith
“displayed limited judgement or insight.” 	(Tr. 27.) 	Smith’s mental status examination also
showed that he “consistently displayed calm, cooperative, and pleasant behavior with normal eye
contact.” (Tr. 27 (citing Exhibits 2F, 6F, 7F, 10F).)
Contrary to Smith’s claim, the ALJ sufficiently addressed supportability and consistency
by citing the relevant exhibits and referring to her previous analysis. (Tr. 31. 29-30.) The medical
findings, as discussed by the ALJ, support and are consistent with SAMC Watson’s opinion that
Smith should be limited to simple work. However, the remaining limitations included in SAMC
Watson’s medical opinion, which include that Smith “can follow two step commands” and “may
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function best in an environment with . . . a supportive management style,” are unsupported by and
inconsistent with the normal mental status examination results. (Tr. 106.)
Thus, the ALJ sufficiently bridged the gap between the evidence and her persuasiveness
determination by citing the record and referencing her previous analysis. See Moira R. v. Comm’n
of Soc. Sec., 2:24-CV-227-Z-BT, 2025 WL 2814156, at *2 (N.D. Tex. Oct. 3, 2025); cf. Probst v.
Kijakazi, EP-22-CV-00286-RFC, 2023 WL: 3237435, at *4 (W.D. Tex. May 3, 2023) (holding the
ALJ’s supportability assessment was deficient because “the Court is left to speculate why Dr.
Friday’s records fail to support his medical opinion.”). 	Since the ALJ previously discussed the
medical history and the mental status examination, the ALJ was not required to redundantly
reanalyze the mental status examination when discussing the persuasiveness of SAMC Watson’s
medical opinion. Cf. Moira R., 2:24-CV-227-Z-BT, 2025 WL 2814156, at *2 (“While Plaintiff
may desire the ALJ to further explain how cited evidence supported his conclusions, ‘citations to
specific evidence in the record constitute an adequate articulation of the supportability and
consistency factors.’”) (quoting Morgan v. Kijakazi, 4:22-cv-631-ALM-KPJ, 2023 WL 6238052,
at *6 (E.D. Tex. Aug. 31, 2023)).
B. Harmless Error
Moreover, even if the Court found error with the ALJ’s explanation, any deficiencies in
her analysis were harmless. It is well-established that “[p]rocedural perfection in administrative
proceedings is not required” as long as “the substantial rights of a party have [not] been affected.”
Mays v. Bowen, 837 F.2d 1362, 1364 (5th Cir. 1988). To be entitled to relief, the claimant must
establish that the ALJ erred and that the ALJ’s error “cast[s] into doubt the existence of substantial
evidence to support the ALJ’s decision.” Morris v. Bowen, 864 F.2d 333, 335 (5th Cir. 1988).
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In this case, since the error alleged by Smith is that the ALJ “did not provide sufficient
explanation of her consideration of the medical opinions,” Smith must “show that if the ALJ had
given further explanation, then she would have adopted” the medical opinions. Miller v. Kijakazi,
22-60541, 2023 WL 234773, at * 4 (5th Cir. Jan 18, 2023) (citing Garcia v. Berryhill, 880 F.3d
700, 704 (5th Cir. 2018)). The harm Smith alleges—that the RFC did not accurately reflect all of
Smith’s limitations—assumes that the ALJ would have adopted SAMC Watson’s opinion if the
ALJ had given further explanation. (See Pl.’s Br. 11-12.) Such an assumption is improper because
Smith “is essentially asking [this Court] to reweigh the evidence to show that [Smith] was
prejudiced by the ALJ’s [alleged] failure to explain, which [this Court] cannot do.” Miller, 2023
WL 234773, at *4 (citing Garcia, 880 F.3d at 704). 	Thus, because Smith does not show that
additional explanation by the ALJ would have led the ALJ to adopt SAMC Watson’s opinion and
integrate it into the RFC, any alleged error is harmless.
CONCLUSION
Based on the foregoing, the decision of the Administrative Law Judge’s decision is
AFFIRMED.
SIGNED February 26, 2026.
JEFFREY L. CURETON
UNITED STATES MAGISTRATE JUDGE
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