Barrett v. Commissioner of Social Security

CourtDistrict Court, W.D. North Carolina
DecidedJanuary 19, 2024
Docket3:23-cv-00321
StatusUnknown

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

Bluebook
Barrett v. Commissioner of Social Security, (W.D.N.C. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION CIVIL ACTION NO. 3:23-CV-00321-KDB

GLORIA S. BARRETT,

Plaintiff,

v. ORDER

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

THIS MATTER is before the Court on Plaintiff Gloria Barrett’s Complaint (Doc. No. 1) and the Parties’ briefs (Doc. Nos. 4, 7). Barrett seeks judicial review of an unfavorable administrative decision denying her applications for disability benefits under the Social Security Act. More specifically, she seeks a remand for further consideration of her maximum RFC because it does not include any mental limitations related to her anxiety and depression. Having reviewed and considered the parties’ briefs and exhibits, the administrative record and applicable authority, and for the reasons set forth below, the Court finds this matter should be remanded to allow the ALJ to reconsider his decision that the claimant is not disabled under the relevant sections of the Act. Accordingly, the Court will REVERSE the Commissioner's decision, and REMAND this matter for further proceedings consistent with this Order. I. LEGAL STANDARD The legal standard for this Court's review of social security benefit determinations is well established. See Shinaberry v. Saul, 952 F.3d 113, 120 (4th Cir. 2020). “The Social Security Administration (SSA) provides benefits to individuals who cannot obtain work because of a physical or mental disability. To determine whether an applicant is entitled to benefits, the agency may hold an informal hearing examining (among other things) the kind and number of jobs available for someone with the applicant's disability and other characteristics. The agency's factual findings on that score are ‘conclusive’ in judicial review of the benefits decision so long as they are supported by ‘substantial evidence.’” Biestek v. Berryhill, 139 S. Ct. 1148, 1151-52, 203 L.Ed.2d 504 (2019) (quoting 42 U.S.C. § 405(g)).

“Under the substantial-evidence standard, a court looks to an existing administrative record and asks whether it contains sufficient evidence to support the agency's factual determinations.” Id. at 1154 (internal quotation marks and alteration omitted). “[T]he threshold for such evidentiary sufficiency is not high. Substantial evidence ... is more than a mere scintilla.1 It means—and means only—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Id. (internal quotation marks and citations omitted). Accordingly, this Court does not review a final decision of the Commissioner de novo, Smith v. Schweiker, 795 F.2d 343, 345 (4th Cir. 1986), and must affirm the Social Security Administration's disability determination “when [the] ALJ has applied correct legal standards and the ALJ's factual findings

are supported by substantial evidence.” Shinaberry, 952 F.3d at 120 (internal citations omitted); see also Hays v. Sullivan, 907 F.2d 1453, 1456 (4th Cir. 1990); Johnson v. Barnhart,

1 As the Fourth Circuit has noted, “[s]tandards are easy to recite, but harder to apply. Part of that difficulty ... lies with confusing terminology like ‘a scintilla of evidence.’ After all, what in the world is a ‘scintilla?’ ... [D]ating back to the nineteenth century, courts have struggled with the ‘distinction between what is a scintilla’ and what is not. Boing v. Raleigh & G.R. Co., 87 N.C. 360 (N.C. 1882) (remarking that the distinction ‘is so narrow that it is often very difficult for a court to decide upon which side of the line’ evidence falls). Recognizing this difficulty, current South Carolina Supreme Court Justice John C. Few once remarked, in jest, that ‘scintilla is Latin for “whatever a judge wants it to mean.”’ ... To overcome the vagaries inherent in the term ‘scintilla,’ courts should not only recite our well-settled standards ... but also actively engage with the [relevant underlying evidence] in analyzing the arguments of the parties.” Sedar v. Reston Town Ctr. Prop., LLC, 988 F.3d 756 (4th Cir. 2021). 434 F.3d 650, 653 (4th Cir. 2005) (“Where conflicting evidence allows reasonable minds to differ as to whether a claimant is disabled, the responsibility for that decision falls on the [ALJ].”). Thus, this Court may not weigh the evidence again, nor substitute its judgment for that of the Commissioner, assuming the Commissioner's final decision is supported by substantial evidence. See Hays, 907 F.2d at 1456. “In reviewing for substantial evidence” in support of an

ALJ's factual findings, “[the reviewing court] do[es] not undertake to reweigh conflicting evidence, make credibility determinations, or substitute [its] judgment for that of the ALJ.” Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012) (internal quotation marks and alteration omitted). Rather, “[w]here conflicting evidence allows reasonable minds to differ as to whether a claimant is disabled,” the court defers to the ALJ's decision. Id. (internal quotation marks omitted); Shinaberry, 952 F.3d at 123. This is true even if the reviewing court disagrees with the outcome—so long as there is “substantial evidence” in the record to support the final decision below. Lester v. Schweiker, 683 F.2d 838, 841 (4th Cir. 1982). However, notwithstanding this limited standard of review of the Commissioner's factual determinations, in all cases the Court

must always ensure that proper legal standards are being followed. II. FACTS AND PROCEDURAL HISTORY Ms. Barrett applied for Title II Disability Insurance Benefits on October 12, 2020, with an alleged onset date of March 13, 2020. See AR 18. Her application was denied on its first review and then again upon reconsideration. Id. On October 29, 2021, Ms. Barrett requested a hearing before an ALJ, which was held on May 11, 2022 before ALJ Joseph Doyle. Id. The ALJ returned an unfavorable decision on August 31, 2022. See AR 18-31. The Appeals Council denied Ms. Barrett’s request for review and thus the ALJ’s decision is the final decision of the Commissioner. Plaintiff timely sought judicial review of that decision under 42 U.S.C. § 405(g). Doc. No. 1. In his decision, the ALJ followed the required five-step sequential evaluation process established by the SSA to determine whether Ms. Barrett was disabled under the law during the relevant period.2 At step one, the ALJ determined that Plaintiff had not engaged in substantial activity since March 13, 2020. AR 20. At step two, the ALJ determined that Ms. Barrett had a severe medically determinable impairment that significantly limits her ability to perform basic

work activities: “fibromyalgia.” AR 21. The ALJ also found that all of Ms.

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Boing v. Raleigh & Gaston Railroad
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Biestek v. Berryhill
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Margaret Shinaberry v. Andrew Saul
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Hancock v. Astrue
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Barrett v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barrett-v-commissioner-of-social-security-ncwd-2024.