Ayers v. Kijakazi

CourtDistrict Court, S.D. Alabama
DecidedMarch 28, 2023
Docket1:21-cv-00461
StatusUnknown

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

Bluebook
Ayers v. Kijakazi, (S.D. Ala. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

RACHEL A. AYERS, * * Plaintiff, * * vs. * CIVIL ACTION NO. 21-00461-B * KILOLO KIJAKAZI, * Acting Commissioner of * Social Security, * * Defendant. *

ORDER Plaintiff Rachel A. Ayers (“Plaintiff”) seeks judicial review of a final decision of the Commissioner of Social Security denying her claim for a period of disability and disability insurance benefits under Title II of the Social Security Act, 42 U.S.C. § 401, et seq. On April 28, 2022, the parties consented to have the undersigned Magistrate Judge conduct any and all proceedings in this case. (Doc. 13). Thus, the action was referred to the undersigned to conduct all proceedings and order the entry of judgment in accordance with 28 U.S.C. § 636(c) and Federal Rule of Civil Procedure 73. (Doc. 14). Upon careful consideration of the administrative record and the memoranda of the parties, it is hereby ORDERED that the decision of the Commissioner be AFFIRMED. I. Procedural History1 Plaintiff protectively filed an application for benefits on October 17, 2019. (Doc. 12 at 225-27). She alleged disability beginning on February 1, 2016, later amended to July 4, 2019, based on degenerative disc disease, bipolar disorder, depression,

anxiety, polycystic ovary syndrome, severe fatigue, a herniated disc, and sciatic nerve pain. (Id. at 225, 228, 245, 249, 344). Plaintiff’s application was denied at the initial stage. (Id. at 111, 127, 129, 147). Upon timely request, Plaintiff was granted a hearing before an Administrative Law Judge (“ALJ”), which was held on February 1, 2021. (Id. at 62, 162). Plaintiff, who was represented by counsel, participated in the hearing by telephone and provided testimony relating to her claims. (Id. at 64-75, 80). A vocational expert (“VE”) also testified at the hearing. (Id. at 76-80). On March 3, 2021, the ALJ issued an unfavorable decision finding that Plaintiff was not disabled. (Id. at 47-56). The Appeals Council denied Plaintiff’s request for review on

September 1, 2021; therefore, the ALJ’s decision became the final decision of the Commissioner. (Id. at 6). Having exhausted her administrative remedies, Plaintiff timely filed the present civil action. (Doc. 1). Oral argument was held on December 5, 2022 (Doc. 19), and the parties agree that

1 The Court’s citations to the transcript in this order refer to the pagination assigned in CM/ECF. this case is now ripe for judicial review and is properly before this Court pursuant to 42 U.S.C. § 405(g). II. Issue on Appeal Whether the ALJ’s RFC assessment is supported by substantial evidence?

III. Factual Background Plaintiff was born in 1987 and was thirty-one years of age on her alleged disability onset date. (Doc. 12 at 228). Plaintiff completed high school and attended some college. (Id. at 250, 429). Plaintiff has a driver’s license and can drive. (Id. at 431). She has past relevant work as a material handler, gas station cashier, and commercial cleaner. (Id. at 68-69, 76-77). At her administrative hearing, Plaintiff testified that she can no longer work because of bipolar disorder, anxiety, depression, and orthopedic issues which cause chronic lower back pain that radiates down her left leg. (Id. at 70-75). IV. Standard of Review In reviewing claims brought under the Act, this Court’s role is a limited one. The Court’s review is limited to determining (1) whether the decision of the Commissioner is supported by substantial evidence and (2) whether the correct legal standards were applied.2 Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir.

2 This Court’s review of the Commissioner’s application of legal principles is plenary. Walker v. Bowen, 826 F.2d 996, 999 (11th Cir. 1987). 1990). A court may not decide the facts anew, reweigh the evidence, or substitute its judgment for that of the Commissioner. Sewell v. Bowen, 792 F.2d 1065, 1067 (11th Cir. 1986). The Commissioner’s findings of fact must be affirmed if they are based upon substantial evidence. Brown v. Sullivan, 921 F.2d 1233, 1235

(11th Cir. 1991). “Substantial evidence is more than a scintilla, but less than a preponderance” and consists of “such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983). In determining whether substantial evidence exists, a reviewing court must consider the record as a whole, taking into account evidence both favorable and unfavorable to the Commissioner’s decision. Chester v. Bowen, 792 F.2d 129, 131 (11th Cir. 1986) (per curiam); Short v. Apfel, 1999 U.S. Dist. LEXIS 10163, at *4 (S.D. Ala. June 14, 1999). V. Statutory and Regulatory Framework An individual who applies for Social Security disability

benefits must prove her disability. See 20 C.F.R. § 404.1512(a)(1). Disability is defined 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); see also 20 C.F.R. § 404.1505(a). The Social Security regulations provide a five-step sequential evaluation process for determining whether a claimant has proven her disability. See 20 C.F.R. § 404.1520. The first two steps of the evaluation require the claimant to prove that she (1) has not engaged in substantial gainful activity

and (2) has a severe impairment or combination of impairments. Carpenter v. Comm’r of Soc. Sec., 614 F. App’x 482, 486 (11th Cir. 2015) (per curiam);3 see 20 C.F.R. § 404.1520(a)(4)(i)-(ii). If the claimant does not meet her burden on either of these two inquiries, she will be found not disabled. Carpenter, 614 F. App’x at 486; see 20 C.F.R. § 404.1520(a)(4)(i)-(ii), (b), (c). If the claimant meets her burden at both of the first two steps, the evaluation proceeds to step three, where if the claimant proves that her impairment or combination of impairments meets or equals a listed impairment and satisfies the duration requirement, she will automatically be found disabled. Phillips v.

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