Booth v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedAugust 2, 2021
Docket2:20-cv-00537
StatusUnknown

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

Opinion

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

GARY D. BOOTH, ) ) Plaintiff, ) ) v. ) Civil Action Number ) 2:20-cv-00537-AKK COMMISSIONER OF SOCIAL ) SECURITY ADMINISTRATION, ) ) Defendant. )

MEMORANDUM OPINION Gary Booth brings this action under 42 U.S.C. § 405(g) of the Social Security Act appealing the final adverse decision of the Commissioner of the Social Security Administration. The court finds that the Administrative Law Judge (“ALJ”) applied the correct legal standards and that substantial evidence does not support the ALJ’s decision. Therefore, the court affirms the ALJ’s decision. I. Booth worked for over 25 years, including as a project estimator. R. 27-28, 62. According to Booth, he lost his job in 2017 because he missed too many days due to debilitating back pain. R. 43. He applied for Disability Insurance and Disability Insurance Benefits (“SSDI”), alleging a disability onset of February 17, 2017, due to lower back pain, nerve damage in the right and left leg, degenerative disc disease, and arthritis. R. 51-52. The Commissioner denied the application, R. 88, and Booth requested and received a hearing before an ALJ, R. 95, 21-50. The

ALJ subsequently issued a decision finding that Booth was not disabled. R. 70-83. The Appeals Council denied review, R. 1, rendering the ALJ’s decision the final decision of the Commissioner. Booth then filed this action for judicial review under

42 U.S.C. § 405(g). 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 standard. 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)(3), the Commissioner’s “factual findings are conclusive if supported by ‘substantial evidence.’” Martin v.

Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990). Thus, the court cannot reconsider the facts, reevaluate the evidence, or substitute its judgment for the Commissioner’s. Id. Instead, it must review the final decision as a whole and determine if it is “‘reasonable and supported by substantial evidence.’” Id. (quoting Bloodsworth v.

Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983)). Substantial evidence refers to “such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Id. (quoting Bloodsworth, 703

F.2d at 1239). As the Supreme Court recently emphasized, this burden “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 (quotation omitted). The ALJ’s conclusions of law, in contrast, receive de novo review. Martin, 894 F.2d at 1529. Reversal is proper if the ALJ applies the

incorrect legal standard or provides an insufficient basis for the court to determine that the correct legal principles have been followed. See Bowen v. Heckler, 748 F.2d 629, 635–36 (11th Cir. 1984).

III. The fundamental inquiry into any application for SSDI is whether the claimant is “disabled,” 42 U.S.C. § 423(d)(2)(A); see also Barnhart v. Thomas, 540 U.S. 20, 21–22 (2003), meaning that he is unable to engage in any substantial gainful activity

due to any medically determinable physical or mental impairment which can be expected to result in death or has lasted or can be expected to last for a continuous period greater than or equal to 12 months, 42 U.S.C. §§ 416(i)(1)(A), 423(d)(1)(A). A. The Social Security Act requires the ALJ to apply a five-step sequential

evaluation process to determine whether a claimant is disabled. 20 C.F.R. § 404.1520(a); accord Phillips v. Barnhart, 357 F.3d 1232, 1237-40 (11th Cir. 2004). Specifically, the ALJ must determine in sequence whether:

(1) the claimant is currently unemployed; (2) the claimant has a severe impairment; (3) the impairment meets or equals one listed by the Commissioner; (4) the claimant is unable to perform his or her past work; and

(5) the claimant is unable to perform any work in the national economy. Phillips, 357 F.3d at 1237. “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.’” McDaniel, 800 F.2d at 1030 (citing 20 C.F.R. § 416.920(a)-(f)). “Once the 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). B. Claimants, such as Booth, alleging disability based on their subjective pain

must meet additional criteria. The Eleventh Circuit applies a three-part “pain standard” when a claimant seeks to establish disability through his own testimony of pain or other subjective symptoms. Holt v. Sullivan, 921 F.2d 1221, 1223 (11th

Cir. 1991). Under that standard, the claimant must show: (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); see 20 C.F.R.

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

Related

Andrew T. Wilson v. Jo Anne B. Barnhart
284 F.3d 1219 (Eleventh Circuit, 2002)
Renee S. Phillips v. Jo Anne B. Barnhart
357 F.3d 1232 (Eleventh Circuit, 2004)
Bobby Dyer v. Jo Anne B. Barnhart
395 F.3d 1206 (Eleventh Circuit, 2005)
Barnhart v. Thomas
540 U.S. 20 (Supreme Court, 2003)
Jane E. Costigan v. Commissioner, Social Security
603 F. App'x 783 (Eleventh Circuit, 2015)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Booth v. Social Security Administration, Commissioner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/booth-v-social-security-administration-commissioner-alnd-2021.