Brown v. Kijakazi (CONSENT)

CourtDistrict Court, M.D. Alabama
DecidedMarch 28, 2023
Docket3:20-cv-00944
StatusUnknown

This text of Brown v. Kijakazi (CONSENT) (Brown v. Kijakazi (CONSENT)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Brown v. Kijakazi (CONSENT), (M.D. Ala. 2023).

Opinion

IN THE DISTRICT COURT OF THE UNITED STATES FOR THE MIDDLE DISTRICT OF ALABAMA EASTERN DIVISION

ELI BROWN, III, ) ) Plaintiff, ) ) v. ) CASE NO. 3:20-cv-944-JTA ) KILOLO KIJAKAZI, ) (WO) Acting Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER Pursuant to 42 U.S.C. § 405(g), the claimant, Eli Brown III (“Brown”), brings this action to review a final decision by the Commissioner of Social Security (“Commissioner”). (Doc. No. 1.)1 The Commissioner denied Brown’s application for a period of disability and disability insurance benefits (“DIB”). The Court construes Brown’s brief in support of his Complaint (Doc. No. 18) as a motion for summary judgment and the Commissioner’s brief in opposition to the Complaint as a motion for summary judgment (Doc. No. 20). The parties have consented to the exercise of dispositive jurisdiction by a magistrate judge pursuant to 28 U.S.C. § 636(c). (Docs. No. 9, 10.) After careful scrutiny of the record and the motions submitted by the parties, the Court finds that Brown’s motion for summary judgment is due to be DENIED, the

1 Document numbers, as they appear on the docket sheet, are designated as “Doc. No.” Commissioner’s motion for summary judgment is due to be GRANTED, and the decision of the Commissioner is due to be AFFIRMED.

I. PROCEDURAL HISTORY AND FACTS Brown was 58 years old at the time of the alleged disability onset date. (R. 25.)2 He is college-educated and previously worked as a supervisor for medical support assistance (unit clerk), truck driver, ammunitions handler, junior ROTC instructor (teacher), and combat life save instructor. (R. 24-25, 41-45, 58.) He alleged a disability onset date of January 31, 2019, due to posttraumatic stress disorder (“PTSD”) and depression. (R. 175.) On February 5, 2019, Brown protectively applied for a period of disability and DIB

under Title II (42 U.S.C. §§ 401, et seq.). (R. 158, 174-184.) The application was denied, and Brown requested an administrative hearing. (R. 15, 95-96.) Following an administrative hearing, the Administrative Law Judge (“ALJ”) denied Brown’s request for benefits in a decision dated May 20, 2020. (R. 12-26.) Brown requested additional review from the Appeals Council, and it denied his request. (R. 1-6.)

Thus, the hearing decision became the final decision of the Commissioner.3 On November 16, 2020, Brown filed a civil action to review the final administrative decision of the Commissioner of Social Security. (Doc. No. 1.) The parties have briefed their respective positions. (Docs. No. 18, 20, 25.) This matter is ripe for review.

2 Citations to the administrative record are consistent with the transcript of administrative proceedings filed in this case. (See Doc. No. 21.) 3 “When, as in this case, the ALJ denies benefits and the [Appeals Council] denies review, [the court] review[s] the ALJ’s decision as the Commissioner's final decision.” Doughty v. Apfel, 245 F.3d 1274, 1278 (11th Cir. 2001) (citation omitted). II. STANDARD OF REVIEW Judicial review of disability claims is limited to whether the Commissioner’s

decision is supported by substantial evidence and whether the correct legal standards were applied. 42 U.S.C. § 405(g); Dyer v. Barnhart, 395 F.3d 1206, 1210 (11th Cir. 2005). “The Commissioner’s factual findings are conclusive” when “supported by substantial evidence.” Doughty v. Apfel, 245 F.3d 1274, 1278 (11th Cir. 2001). “Substantial evidence” is more than a mere scintilla and is “such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Crawford v. Comm’r of Soc. Sec., 363 F.3d

1155, 1158 (11th Cir. 2004) (quoting Lewis v. Callahan, 125 F.3d 1346, 1349 (11th Cir. 1997)). Even if the Commissioner’s decision is not supported by a preponderance of the evidence, the findings must be affirmed if they are supported by substantial evidence. Id. at 1158-59; see also Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990). The court may not find new facts, reweigh evidence, or substitute its own judgment for that of the

Commissioner. Bailey v. Soc. Sec. Admin., Comm’r, 791 F. App’x 136, 139 (11th Cir. 2019); Phillips v. Barnhart, 357 F.3d 1232, 1240 n.8 (11th Cir. 2004); Dyer, 395 F.3d at 1210. However, the Commissioner’s conclusions of law are not entitled to the same deference as findings of fact and are reviewed de novo. Ingram v. Comm’r of Soc. Sec. Admin., 496 F.3d 1253, 1260 (11th Cir. 2007).

Sentence four of 42 U.S.C. § 405(g) authorizes the district court to “enter, upon the pleadings and transcript of the record, a judgment affirming, modifying, or reversing the decision of the Commissioner of Social Security, with or without remanding the cause for a rehearing.” 42 U.S.C. § 405(g). The district court may remand a case to the Commissioner for a rehearing if the court finds “either . . . the decision is not supported by substantial evidence, or . . . the Commissioner or the ALJ incorrectly applied the law relevant to the

disability claim.” Jackson v. Chater, 99 F.3d 1086, 1092 (11th Cir. 1996). III. STANDARD FOR DETERMINING DISABILITY An individual who files an application for Social Security DIB must prove that he is disabled. See 20 C.F.R. § 404.1505. The Act defines “disability” as 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 12 months.” 42 U.S.C. § 423(d)(1)(A); 20 C.F.R. § 404.1505(a). Disability under the Act is determined under a five-step sequential evaluation process. See 20 C.F.R. § 404.1520. The evaluation is made at the hearing conducted by an administrative law judge (“ALJ”). See Washington v. Comm’r of Soc. Sec., 906 F.3d 1353,

1359 (11th Cir. 2018). First, the ALJ must determine whether the claimant is currently engaged in substantial gainful activity. 20 C.F.R. § 404.1520(b). “Substantial gainful activity” is work activity that involves significant physical or mental activities. 20 C.F.R.

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Brown v. Kijakazi (CONSENT), Counsel Stack Legal Research, https://law.counselstack.com/opinion/brown-v-kijakazi-consent-almd-2023.