Abrams v. Kijakazi (CONSENT)

CourtDistrict Court, M.D. Alabama
DecidedAugust 31, 2023
Docket2:22-cv-00335
StatusUnknown

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

Bluebook
Abrams v. Kijakazi (CONSENT), (M.D. Ala. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

TAMIKA ABRAMS, ) ) Plaintiff, ) ) v. ) CASE NO. 2:22-cv-335-JTA ) KILOLO KIJAKAZI, ) (WO) Acting Commissioner of Social Security, ) ) Defendant. ) MEMORANDUM OPINION AND ORDER Pursuant to 42 U.S.C. § 405(g), the claimant, Tamika Abrams (“Abrams”) brings this action to review a final decision by the Commissioner of Social Security (“Commissioner”). (Doc. No. 1.)1 The Commissioner denied Abrams’s applications for a period of disability, Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”). The Court construes Abram’s brief in support of her Complaint (Doc. No. 11) as a motion for summary judgment and the Commissioner’s brief in opposition to the Complaint as a motion for summary judgment (Doc. No. 12). The parties have consented to the exercise of dispositive jurisdiction by a magistrate judge pursuant to 28 U.S.C. § 636(c). (Docs. No. 14, 15.) After careful scrutiny of the record and the motions submitted by the parties, the Court finds that Abrams’s motion for summary judgment is due to be DENIED, the

1 Document numbers, as they appear on the docket sheet, are designated as “Doc. No.” Commissioner’s motion for summary judgment is due to be GRANTED, and the decision of the Commissioner is due to be AFFIRMED.

I. PROCEDURAL HISTORY AND FACTS Abrams was 40 years old at the time of the administrative hearing held on September 8, 2021. (R. 34, 41.)2 She obtained her GED and completed one year of college. (R. 42, 77.) She previously worked as a certified nursing assistant, auto part assembler, cook, and cashier. (R. 24, 43-44, 56-57.) She alleged a disability onset of January 1, 2017, and later amended the onset date to March 26, 2020. (R. 42.)

On May 29, 2019, Abrams filed applications for a period of disability and DIB under Title II of the Social Security Act and for SSI under Title XVI of the Social Security Act. (R. 15, 39.) These applications were denied initially on July 19, 2019. (R. 15.) Following an administrative hearing, the Administrative Law Judge (“ALJ”) denied Abrams’s request for benefits in a decision dated September 29, 2021. (R. 12-26.) Abrams requested review

by the Appeals Council and the Appeals Council denied review. (R. 1-3.) Thus, the hearing decision became the final decision of the Commissioner.3 On June 3, 2022, Abrams filed the instant action seeking review of the Commissioner’s final decision. (Doc. No. 1.) The parties have briefed their respective positions and this matter is ripe for review.

2 Citations to the administrative record are consistent with the transcript of administrative proceedings filed in this case. (See Doc. No. 13.) 3 “When, as in this case, the ALJ denies benefits and the [Appeals Council] denies review, [the court] review[s] the ALJ’s decision as the Commissioner’s final decision.” Doughty v. Apfel, 245 F.3d 1274, 1278 (11th Cir. 2001) (citation omitted). II. STANDARD OF REVIEW Judicial review of disability claims is limited to whether the Commissioner’s

decision is supported by substantial evidence and whether the correct legal standards were applied. 42 U.S.C. § 405(g); Dyer v. Barnhart, 395 F.3d 1206, 1210 (11th Cir. 2005). “The Commissioner’s factual findings are conclusive” when “supported by substantial evidence.” Doughty v. Apfel, 245 F.3d 1274, 1278 (11th Cir. 2001). “Substantial evidence” is more than a mere scintilla and is “such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Crawford v. Comm’r of Soc.

Sec., 363 F.3d 1155, 1158 (11th Cir. 2004) (quoting Lewis v. Callahan, 125 F.3d 1346, 1349 (11th Cir. 1997)). Even if the Commissioner’s decision is not supported by a preponderance of the evidence, the findings must be affirmed if they are supported by substantial evidence. Id. at 1158-59; see also Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990). The court may not find new facts, reweigh evidence, or substitute its own

judgment for that of the Commissioner. Bailey v. Soc. Sec. Admin., Comm’r, 791 F. App’x 136, 139 (11th Cir. 2019); Phillips v. Barnhart, 357 F.3d 1232, 1240 n.8 (11th Cir. 2004); Dyer, 395 F.3d at 1210. However, the Commissioner’s conclusions of law are not entitled to the same deference as findings of fact and are reviewed de novo. Ingram v. Comm’r of Soc. Sec. Admin., 496 F.3d 1253, 1260 (11th Cir. 2007).

Sentence four of 42 U.S.C. § 405(g) authorizes the district court to “enter, upon the pleadings and transcript of the record, a judgment affirming, modifying, or reversing the decision of the Commissioner of Social Security, with or without remanding the cause for a rehearing.” 42 U.S.C. § 405(g). The district court may remand a case to the Commissioner for a rehearing if the court finds “either . . . the decision is not supported by substantial evidence, or . . . the Commissioner or the ALJ incorrectly applied the law

relevant to the disability claim.” Jackson v. Chater, 99 F.3d 1086, 1092 (11th Cir. 1996). III. STANDARD FOR DETERMINING DISABILITY An individual who files an application for Social Security DIB and SSI must prove that she is disabled.4 See 20 C.F.R. § 404.1505; 20 C.F.R. § 416.920. 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); 20 C.F.R. § 404.1505(a). Disability under the Act is determined under a five-step sequential evaluation process. See 20 C.F.R. § 404.1520. The evaluation is made at the hearing conducted by the ALJ. See Washington v. Comm’r of Soc. Sec., 906 F.3d 1353, 1359 (11th Cir. 2018).

First, the ALJ must determine whether the claimant is currently engaged in substantial gainful activity. 20 C.F.R. § 404.1520(b).

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