Briggs v. Commissioner of the Social Security Administration

District Court, D. South Carolina·Decided August 5, 2025·No. 4:24-cv-07520·Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION Angela Ann Briggs, ) Civil Action No.: 4:24-cv-07520-RMG-TER Plaintiff, ) ) -vs- ) ) Report and Recommendation Frank Bisignano,1 ) Commissioner of Social Security ) Administration, ) ) Defendant. ) ___________________________________ ) This is an action brought pursuant to Section 205(g) of the Social Security Act, as amended, 42 U.S.C. Section 405(g), to obtain judicial review of a “final decision” of the Commissioner of Social Security, a partially favorable disposition of Plaintiff’s claim for disability insurance benefits (DIB) and supplemental security income (SSI). The only issues before the Court are whether the findings of fact are supported by substantial evidence and whether proper legal standards have been applied. I. RELEVANT BACKGROUND A. Procedural History Plaintiff filed an application in April 2021, with an amended alleged onset date of September 10, 2019. (Tr. 16). The date was moved because that was when Plaintiff was first diagnosed with an impairment referenced in Exhibit 13F/37; the same date is listed on a right foot x-ray and exam. (Tr. 47, 1356-1357). Her claims were denied initially and upon reconsideration. Thereafter, Plaintiff filed a request for a hearing. A hearing was held in March 2024, at which time Plaintiff and a 1Frank Bisignano became the Commissioner of Social Security in May 2025. Pursuant to Fed. R. Civ. P. 25(d), he is automatically substituted. vocational expert (VE) testified. The Administrative Law Judge (ALJ) issued a partially favorable decision on April 17, 2024, finding that Plaintiff was disabled beginning on March 9, 2024. (Tr. 29). Plaintiff filed a request for review of the ALJ’s decision. The Appeals Council denied the request for review in October 2024. Plaintiff filed this action in December 2024. (ECF No. 1).

B. Introductory Facts Plaintiff was born in March 1974, and was forty-seven years old on the date last insured. (Tr. 100). Plaintiff has past relevant work as a sign technician and a composite job of cashier assistant/bookkeeper and cashier/front end supervisor. (Tr. 27). Plaintiff alleges disability originally due to “fms, sciatic nerve, rls, plantar fascia, ibs, [and] allergies.” (Tr. 100). C. The ALJ’s Decision In the decision of October 2024, the ALJ made the following findings of fact and conclusions

of law (Tr. 16-28): 1. The claimant meets the insured status requirements of the Social Security Act through December 31, 2021. 2. The claimant has not engaged in substantial gainful activity since September 10, 2019, the amended alleged onset date (20 CFR 404.1571 et seq., and 416.971 et seq.). 3. Since the amended alleged onset date of disability, September 10, 2019, the claimant has had the following severe impairments: degenerative disc disease of the cervical spine, degenerative joint disease of the bilateral shoulders, fibromyalgia, bilateral carpal tunnel syndrome status post right-sided release, osteoarthritis and meniscus tearing of the left knee, and obesity (20 CFR 404.1520(c) and 416.920(c)). 4. Since September 10, 2019, the claimant has not had an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1 (20 CFR 404.1520(d), 404.1525, 404.1526, 416.920(d), 416.925 and 416.926). 2 5. After careful consideration of the entire record, the undersigned finds that since September 10, 2019, the claimant has the residual functional capacity to perform sedentary work as defined in 20 CFR 404.1567(a) and 416.967(a), except she can never climb ladders, ropes, or scaffolds and can occasionally balance, stoop, kneel, crouch, crawl, and climb ramps and stairs. She can frequently engage in pushing and pulling with her bilateral upper and lower extremities. She can frequently engage in handling, fingering, and feeling with her bilateral upper extremities, and can occasionally engage in bilateral overhead reaching. She can tolerate occasional exposure to vibration, and must avoid all exposure to hazards such as unprotected heights and moving machinery. She remains capable of simple and detailed, but not complex tasks, can understand, remember, and carry out simple work-related instructions, and can make simple work-related decisions. She will be off task for 10% of the workday, exclusive of regularly scheduled breaks, and will be absent from work 1 day each month on an unscheduled basis. 6. Since September 10, 2019, the claimant has been unable to perform any past relevant work (20 CFR 404.1565 and 416.965). 7. Prior to the established disability onset date, the claimant was a younger individual age 18-49a younger individual age 45-49. On March 9, 2024, the claimant’s age category changed to an individual closely approaching advanced age (20 CFR 404.1563 and 416.963).(errors in original) 8. The claimant has at least a high school education (20 CFR 404.1564 and 416.964). 9. Prior to March 9, 2024, transferability of job skills is not material to the determination of disability because using the Medical-Vocational Rules as a framework supports a finding that the claimant is “not disabled” whether or not the claimant has transferable job skills. Beginning on March 9, 2024, the claimant has not been able to transfer job skills to other occupations (See SSR 82-41 and 20 CFR Part 404, Subpart P, Appendix 2). 10. Prior to March 9, 2024, the date the claimant’s age category changed, considering the claimant’s age, education, work experience, and residual functional capacity, there were jobs that existed in significant numbers in the national economy that the claimant could have performed (20 CFR 404.1569, 404.1569a, 416.969, and 416.969a). 11. Beginning on March 9, 2024, the date the claimant’s age category changed, considering the claimant’s age, education, work experience, and residual functional capacity, there are no jobs that exist in significant 3 numbers in the national economy that the claimant could perform (20 CFR 404.1560(c), 404.1566, 416.960(c), and 416.966). 12. The claimant was not disabled prior to March 9, 2024, but became disabled on that date and has continued to be disabled through the date of this decision. Her disability is expected to last twelve months past the onset date (20 CFR 404.1520(g) and 416.920(g)). II. DISCUSSION Plaintiff’s brief is brief, and Plaintiff attached the entire record to the brief. (ECF No. 23).

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