Blake v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedAugust 25, 2021
Docket4:20-cv-00983
StatusUnknown

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

Bluebook
Blake v. Social Security Administration, Commissioner, (N.D. Ala. 2021).

Opinion

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

WHITNEY BLAKE, ) ) Plaintiff, ) Civil Action Number v. ) 4:20-cv-00983-AKK ) KILOLO KIJAKAZI, Acting ) Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM OPINION Whitney Blake brings this action under 42 U.S.C. § 405(g) of the Social Security Act (the Act) seeking review of the final adverse decision of the Commissioner of the Social Security Administration. Doc. 1. The court finds that the Administrative Law Judge applied the correct legal standard and that his decision, which has become that of the Commissioner, is supported by substantial evidence. The court therefore AFFIRMS the decision denying benefits. I. Whitney Blake applied for Supplemental Security Income on January 23, 2018, alleging migraines; fibromyalgia; cervical degenerative disease; depression; and bipolar, anxiety, and obsessive disorders. Doc. 14 at 1–2; R. 17. Blake previously worked as a U.S. Census Bureau enumerator, a cashier at a fast-food restaurant, and an EMT, but she alleged that her migraines affected her ability to work and thus rendered her employment history spotty. R. 214–21. After her SSI

claim was denied on March 19, 2018, at Blake’s request, a video hearing with Blake, her attorney, an ALJ, and a vocational expert was held on October 2, 2019. See id. Thereafter, the ALJ entered a decision finding that Blake was not disabled. R. 14.

The SSA Appeals Council denied Blake’s request for review, rendering the ALJ’s decision the final decision of the Commissioner. R. 3. Blake subsequently filed this petition for review pursuant to 42 U.S.C. § 405(g). Doc. 1. II.

This court’s review is limited to determining whether the record contains substantial evidence to sustain the ALJ’s decision and whether the ALJ applied the correct legal standards. See 42 U.S.C. § 405(g); Chester v. Bowen, 792 F.2d 129,

131 (11th Cir. 1986). Under 42 U.S.C. §§ 405(g) and 1383(c), the Commissioner’s “factual findings are conclusive if supported by ‘substantial evidence.’” Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990). The court may not reconsider the facts, reevaluate the evidence, or substitute its judgment for the Commissioner’s. Id.

Rather, the court must review the final decision in its entirety to determine whether it is “‘reasonable and supported by substantial evidence.’” Id. (quoting Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983)). Substantial evidence is defined as “such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Id.

(quoting Bloodsworth, 703 F.2d at 1239). “[T]he threshold for such evidentiary sufficiency is not high.” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019). Rather, substantial evidence falls somewhere between a “scintilla” and a “preponderance of

evidence.” Martin, 894 F.2d at 1529. If substantial evidence supports the Commissioner’s factual findings, then the court must affirm, even if the evidence preponderates against those findings. See id. However, this “does not yield automatic affirmance” despite the limited scope of judicial review, Lamb v. Bowen,

847 F.2d 698, 701 (11th Cir. 1988), and reviewing courts are not to act as mere “automatons[,]” Bloodsworth, 703 F.2d at 1239 (internal quotations omitted). By contrast, courts review conclusions of law de novo. Martin, 894 F.2d at 1529.

III. To qualify for disability benefits, a claimant must show 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); 416(i)(1). A physical or mental impairment is “an impairment that results from anatomical, physiological, or psychological abnormalities which are demonstrated by medically acceptable clinical and laboratory diagnostic techniques.” Id. § 423(d)(3).

Determination of disability under the Act requires a five-step analysis. 20 C.F.R. § 404.1520(a). Specifically, the ALJ must determine, in the following order: (1) whether the claimant is currently unemployed; (2) whether the claimant has a severe impairment; (3) whether the impairment meets or equals one listed by the Commissioner; (4) whether the claimant is unable to perform his or her past work; and (5) whether the claimant is unable to perform any work in the national economy.

McDaniel v. Bowen, 800 F.2d 1026, 1030 (11th Cir. 1986). “An affirmative answer to any of the above questions leads either to the next question, or, on steps three and five, to a finding of disability. A negative answer to any question, other than step three, leads to a determination of ‘not disabled.’” Id. (citing 20 C.F.R. § 416.920(a)- (f)). “Once [a] finding is made that a claimant cannot return to prior work[,] the burden of proof shifts to the [Commissioner] to show other work the claimant can do.” Foote v. Chater, 67 F.3d 1553, 1559 (11th Cir. 1995). When a claimant seeks to establish a disability through her own testimony concerning “pain or other subjective symptoms,” courts in the Eleventh Circuit apply a three-part test that requires “(1) evidence of an underlying medical condition; and (2) either (a) objective medical evidence confirming the severity of the alleged pain;

or (b) that the objectively determined medical condition can reasonably be expected to give rise to the claimed pain.” Wilson v. Barnhart, 284 F.3d 1219, 1225 (11th Cir. 2002); Holt v. Sullivan, 921 F.2d 1221, 1223 (11th Cir. 1991). “If the ALJ

discredits subjective testimony, he must articulate explicit and adequate reasons for doing so,” and “[f]ailure to articulate the reasons for discrediting subjective testimony requires, as a matter of law, that the testimony be accepted as true.”

Wilson, 284 F.3d at 1225 (citing Hale v. Bowen, 831 F.2d 1007, 1011 (11th Cir. 1987); Cannon v.

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