Blum v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedNovember 29, 2021
Docket5:20-cv-01538
StatusUnknown

This text of Blum v. Social Security Administration, Commissioner (Blum 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
Blum v. Social Security Administration, Commissioner, (N.D. Ala. 2021).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA NORTHEASTERN DIVISION ROGER BLUM, JR., ) ) Plaintiff, ) ) v. ) Case No.: 5:20-cv-01538-LCB ) KILOLO KIJAKAZI, ) Acting Commissioner of Social ) Security, ) ) Defendant. ) MEMORANDUM OPINION On October 4, 2021, Plaintiff, Roger Blum, Jr., filed a Complaint seeking judicial review of the Commissioner of the Social Security Administration’s adverse action in accordance with 42 U.S.C. § 405(g). (Doc. 1). The Commissioner filed an Answer on May 17, 2021. (Doc. 18). Blum filed a Brief in Support of his position on July 1, 2021 (Doc. 20), and the Commissioner filed a Response on August 2, 2021. (Doc. 21). Blum did not file a Reply. For the following reasons, the Commissioner’s final decision is AFFIRMED. I. Background Blum filed an application for social security disability benefits on October 11, 2018. (Tr. 119-20).1 His claim was denied was November 21, 2018. (Tr. 57-61).

1 “Tr” denotes the page number assigned in the administrative record filed by the Commissioner. See (Docs. 18-3 to 18-8). After his claim was denied, Blum requested a hearing before an Administrative Law Judge. (Tr. 62-63). That hearing took place on December 9, 2019. Blum was

represented by counsel. (Tr. 26-42). Charles Wheeler, a Vocational Expert, also testified at the hearing. (Tr. 34-36). The ALJ issued an adverse decision on January 6, 2020. (Tr. 15-25). Blum requested review of the ALJ’s decision before

the Social Security Appeals Council, and the Council denied his request for review on August 6, 2020. (Tr. 1-3). This lawsuit followed. II. The ALJ’s Analysis The ALJ issued a written opinion explaining her decision following Blum’s

evidentiary hearing. (Tr. 18-22). In her order, the ALJ followed the five-step evaluation process set out by the Social Security Act. 20 C.F.R. § 416.920(a). In accordance with that standard, each step is followed sequentially and, if it’s

determined that the claimant is or isn’t disabled at a particular step, the ALJ won’t proceed to the next step. The first step of the five-step analysis requires the ALJ to determine whether the claimant is engaging in substantial gainful activity, which is defined as work

involving significant physical or mental activities usually done for pay or profit. If a claimant is engaged in substantial gainful activity, he is not disabled, and the inquiry stops. Otherwise, the ALJ will proceed to step two. In the present case, the ALJ

found that Blum had not engaged in substantial gainful activity during the period from his alleged onset date of September 30, 2021 through his date last insured of March 31, 2017. (Tr. 20). Accordingly, the ALJ moved to step two.

At step two, ALJs must determine whether the claimant has a medically determinable impairment that is “severe” or a combination of impairments that is “severe.” 20 C.F.R. § 416.920(c). An impairment is severe if it “significantly limits

[a claimant’s] physical or mental ability to do basic work activities. . . .” Id. If a claimant does not have a severe impairment, he is not disabled, and the inquiry ends. The ALJ found that Blum had medically determinable impairments of insomnia and chronic pain. (Tr. 20). The ALJ found, however, that Blum’s neck problems, status

post leg fracture, nonmalignant brain tumor, poor hearing, and learning disability were not medically determinable impairments due to a lack of objective evidence. Id. Accordingly, the ALJ found that Blum did not have a severe impairment or

combination of impairments. (Tr. 21). The ALJ therefore concluded Blum was not disabled as defined by the Social Security Administration. III. Standard of Review The Court must determine whether the Commissioner’s decision is supported

by substantial evidence and whether the correct legal standards were applied. Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011). “Substantial evidence is more than a scintilla and is such relevant evidence as a reasonable person

would accept as adequate to support a conclusion.” Id. (internal citation and quotation marks omitted). “This limited review precludes deciding facts anew, making credibility determinations, or re-weighing the evidence.” Moore v. Barnhart,

405 F.3d 1208, 1211 (11th Cir. 2005) (per curiam). Thus, while a reviewing court must scrutinize the record as a whole, the court must affirm the Commissioner’s decision if it is supported by substantial evidence—even if the evidence

preponderates against the Commissioner’s findings. E.g., Henry v. Comm’r of Soc. Sec., 802 F.3d 1264, 1267 (11th Cir. 2015) (per curiam); Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983). IV. Blum’s Argument

Blum presents one issue for review, asserting it constitutes reversible error. (Doc. 20 at 6). Blum contends the ALJ’s determination that Blum did not suffer from a severe impairment during the relevant period was not supported by substantial

evidence. As explained below, Blum’s argument is meritless. At step two, a claimant must satisfy three factors to show they suffer from a severe impairment. First, the claimant must show that he is not working because he suffers from an impairment. Impairments must result from an anatomical

physiological, or psychological abnormality which can be shown by medically acceptable clinical and laboratory diagnostic techniques. 20 C.F.R. § 404.1502(c)- (g). Second, the impairment must be severe. An impairment is severe when it

significantly limits a claimant’s physical or mental ability to do basic work activities. 20 C.F.R. § 404.1520(c). Third, the claimant must have suffered from the impairment or must expect to suffer from the impairment for at least twelve months.

20 C.F.R. § 404.1509. As an initial matter, the claimant bears the burden of showing disability. Moore, 405 F.3d at 1211. “Unless the claimant can prove, as early as step two, that

[he] is suffering from a severe impairment, [he] will be denied disability benefits.” McDaniel v. Bowen, 800 F.2d 1026, 1031 (11th Cir. 1986). That being said, “[t]he claimant’s burden at step two is mild.” Id. To find that an impairment is not severe, the ALJ must determine “the abnormality is so slight and its effect so minimal that

it would clearly not be expected to interfere with the individual’s ability to work, irrespective of age, education, or work experience.” Id. Blum argues that the ALJ did not consider the record as a whole and instead

relied on isolated notations in the record. (Doc. 20 at 7). In support, Blum cites Chambers v.

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Related

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)
Winschel v. Commissioner of Social Security
631 F.3d 1176 (Eleventh Circuit, 2011)
Chambers v. Astrue
671 F. Supp. 2d 1253 (N.D. Alabama, 2009)
Thomas Scott Henry v. Commissioner of Social Security
802 F.3d 1264 (Eleventh Circuit, 2015)

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Blum v. Social Security Administration, Commissioner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/blum-v-social-security-administration-commissioner-alnd-2021.