Anderson v. Commissioner of Social Security

CourtDistrict Court, M.D. Florida
DecidedMarch 28, 2025
Docket2:23-cv-00975
StatusUnknown

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

Bluebook
Anderson v. Commissioner of Social Security, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA FORT MYERS DIVISION

DANIELLE R. ANDERSON,

Plaintiff,

v. 2:23-cv-975-NPM

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

OPINION AND ORDER Plaintiff Danielle R. Anderson seeks judicial review of a denial of Social Security disability benefits. The Commissioner of the Social Security Administration filed the transcript of the proceedings (Doc. 11),1 Anderson filed an opening brief (Doc. 16), the Commissioner responded (Doc. 20), and Anderson replied (Doc. 22). As discussed in this opinion and order, the decision of the Commissioner is affirmed. I. Eligibility for Disability Benefits and the Administration’s Decision A. Eligibility The Social Security Act and related regulations define disability as the inability to do any substantial gainful activity by reason of one or more medically determinable physical or mental impairments that can be expected to result in death

1 Cited as “Tr.” followed by the appropriate page number. or that have lasted or can be expected to last for a continuous period of not less than twelve months.2 Depending on its nature and severity, an impairment limits

exertional abilities like walking or lifting, non-exertional abilities like seeing or hearing, tolerances for workplace conditions like noise or fumes, or aptitudes necessary to do most jobs such as using judgment or dealing with people.3 And when

functional limitations preclude both a return to past work and doing any other work sufficiently available in the national economy (or an impairment meets or equals the severity criteria for a disabling impairment as defined in the regulatory “Listing of Impairments”), the person is disabled for purposes of the Act.4

B. Factual and procedural history On October 12, 2020, Anderson applied for supplemental security income.5 (Tr. 349-367). She asserted an alleged onset date of October 12, 2020, alleging

disability due to the following: lupus, rheumatoid arthritis, ulcerative colitis, endometriosis, HPV, anxiety, depression, insomnia, chronic migraines, and

2 See 42 U.S.C. §§ 416(i), 423(d), 1382c(a)(3); 20 C.F.R. § 416.905. 3 See 20 C.F.R. §§ 416.913(a)(2)(i)(A)-(D) (discussing the various categories of work-related abilities), 416.922(b) (providing examples of abilities and aptitudes necessary to do most jobs), 416.945(b)-(d) (discussing physical, mental, and other abilities that may be affected by an impairment), 416.994(b)(1)(iv) (defining functional capacity to do basic work activities). 4 See 20 C.F.R. § 416.911(a). 5 Anderson also applied for disability insurance benefits, but she agreed to waive the claim as she did not earn enough quarters of coverage to qualify for disability insurance as of the alleged onset date. (Tr. 11, 378). bronchitis. (Tr. 121, 376-378, 383). As of the alleged onset date, Anderson was 27 years old and had a GED. (Tr. 121, 125). She previously worked as a delivery driver

and a Walmart overnight stocker. (Tr. 123-24). On behalf of the administration, a state agency 6 reviewed and denied Anderson’s application initially on April 5, 2021, and upon reconsideration on

September 14, 2021. (Tr. 204-09, 217-22, 226-32). At Anderson’s request, Administrative Law Judge (ALJ) Mario Silva held a hearing on January 25, 2022, obtained physical and psychological consultative exams, and then conducted a supplemental hearing on September 19, 2022. Anderson was represented by counsel

during both hearings. On December 27, 2022, ALJ Silva issued an unfavorable decision finding Anderson not disabled. (Tr. 8-27). Anderson’s request for review by the administration’s Appeals Council was denied, making the ALJ’s decision

final. (Tr. 1-4). Anderson then brought the matter to this court, and the case is ripe for judicial review. C. The ALJ’s decision The ALJ must perform a five-step sequential evaluation to determine if a

claimant is disabled. 20 C.F.R. § 416.920(a)(1). This five-step process determines: (1) whether the claimant is engaged in substantial gainful activity; (2) if not, whether the claimant has a severe impairment or combination of impairments; (3) if so, whether these impairments meet or equal an

6 In Florida, a federally funded state agency develops evidence and makes the initial determination whether a claimant is disabled. See 42 U.S.C. § 421(a); 20 C.F.R. § 416.903(a). impairment listed in the Listing of Impairments; (4) if not, whether the claimant has the residual functional capacity (“RFC”) to perform [her] past relevant work; and (5) if not, whether, in light of [her] age, education, and work experience, the claimant can perform other work that exists in significant numbers in the national economy.

Atha v. Comm’r, Soc. Sec. Admin., 616 F. App’x 931, 933 (11th Cir. 2015) (internal quotation omitted); see also 20 C.F.R. § 416.920(a)(4). The governing regulations provide that the Social Security Administration conducts this “administrative review process in an informal, non-adversarial manner.” 20 C.F.R. § 416.1400(b). Unlike judicial proceedings, Social Security Administration hearings “are inquisitorial rather than adversarial.” Washington v. Comm’r of Soc. Sec., 906 F.3d 1353, 1364 (11th Cir. 2018) (quoting Sims v. Apfel, 530 U.S. 103, 111 (2000) (plurality opinion)). “Because Social Security hearings basically are inquisitorial in nature, ‘[i]t is the ALJ’s duty to investigate the facts and develop the arguments both for and against granting benefits.’” Id. Indeed, “at the

hearing stage, the commissioner does not have a representative that appears ‘before the ALJ to oppose the claim for benefits.’” Id. (quoting Crawford & Co. v. Apfel, 235 F.3d 1298, 1304 (11th Cir. 2000)). “Thus, ‘the ALJ has a basic duty to develop a full and fair record. This is an onerous task, as the ALJ must scrupulously and

conscientiously probe into, inquire of, and explore for all relevant facts.’” Id. (quoting Henry v. Comm’r of Soc. Sec., 802 F.3d 1264, 1267 (11th Cir. 2015)). Nonetheless, while the claimant is relieved of the burden of production during step five as to whether there are enough jobs someone like the claimant can perform,

the claimant otherwise has the burdens of production and persuasion throughout the process. See 20 C.F.R. § 416.912 (providing that the claimant must prove disability); see also Moore v. Barnhart, 405 F.3d 1208, 1211 (11th Cir. 2005) (noting the

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Dorothy Couch v. Michael J. Astrue
267 F. App'x 853 (Eleventh Circuit, 2008)
Billy D. Crawford v. Comm. of Social Security
363 F.3d 1155 (Eleventh Circuit, 2004)
Bobby Dyer v. Jo Anne B. Barnhart
395 F.3d 1206 (Eleventh Circuit, 2005)
Christi L. Moore v. Jo Anne B. Barnhart
405 F.3d 1208 (Eleventh Circuit, 2005)
Sean Pinion v. Commissioner of Social Security
522 F. App'x 580 (Eleventh Circuit, 2013)
Sims v. Apfel
530 U.S. 103 (Supreme Court, 2000)
Thomas Scott Henry v. Commissioner of Social Security
802 F.3d 1264 (Eleventh Circuit, 2015)
Lindell Washington v. Commissioner of Social Security
906 F.3d 1353 (Eleventh Circuit, 2018)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Jackie Noble v. Commissioner of Social Security
963 F.3d 1317 (Eleventh Circuit, 2020)
Rachel Goode v. Commissioner of Social Security
966 F.3d 1277 (Eleventh Circuit, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Anderson v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/anderson-v-commissioner-of-social-security-flmd-2025.