Chauncey v. Saul

CourtDistrict Court, D. South Dakota
DecidedSeptember 30, 2022
Docket5:21-cv-05014
StatusUnknown

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

Bluebook
Chauncey v. Saul, (D.S.D. 2022).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH DAKOTA WESTERN DIVISION

THOMAS C.1, 5:21-CV-05014-DW

Plaintiff,

vs. REDACTED ORDER

KILOLO KIJAKAZI, ACTING COMMISSIONER OF THE SOCIAL SECURITY ADMINISTRATION;

Defendant.

INTRODUCTION On March 5, 2021, claimant Thomas C. filed a complaint appealing the final decision of Andrew Saul2, the acting Commissioner of the Social Security Administration, finding him not disabled. (Doc. 1). Defendant denies claimant is entitled to benefits. (Doc. 12). The court issued a briefing schedule requiring the parties to file a joint statement of materials facts (“JSMF”). (Doc. 14). For

1 The Administrative Office of the Judiciary suggested the court be more mindful of protecting from public access the private information in Social Security opinions and orders. For that reason, the Western Division of the District of South Dakota will use the first name and last initial of every non- governmental person mentioned in the opinion. This includes the names of non-governmental parties appearing in case captions.

2 Dr. Kilolo Kijakazi became the Acting Commissioner of Social Security on July 9, 2021. Pursuant to Fed. R. Civ. P. 25(d), Dr. Kijakazi is automatically substituted for Andrew Saul as the defendant in all pending social security cases. No further action need be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g). the reasons stated below, claimant’s motion to reverse the decision of the Commissioner (Doc. 20) is granted. FACTS AND PROCEDURAL HISTORY

The parties’ JSMF (Doc. 15) is incorporated by reference. Further recitation of the salient facts is incorporated in the discussion section of this order. On September 1, 2017, Mr. C. filed an application for Social Security disability benefits alleging an onset of disability date of May 1, 2016. (AR at p. 23).3 The claim was initially denied on December 28, 2017, and denied upon reconsideration on May 23, 2018. (AR at p. 23). Mr. C. requested an administrative hearing on June 5, 2018, and one was held on February 26,

2020. (AR at p. 23). On April 7, 2020, the ALJ issued a written decision denying benefits. (AR at pp. 20-38). Mr. C. subsequently sought appellate review; his request was denied, making the decision of the ALJ final. (AR at p. 1). It is from this decision that Mr. C. timely appeals. The issue before this court is whether the Administrative Law Judge’s (ALJ) decision of April 7, 2020, that Mr. C. was not “under a disability, as defined in the Social Security Act, from May 1, 2016, through [April 7, 2020]” is supported by substantial evidence on the record as a whole. (AR at p. 38). See

also Howard v. Massanari, 255 F.3d 577, 580 (8th Cir. 2001).

3 The court will cite to information in the administrative record as “AR at p. ___.” STANDARD OF REVIEW The Commissioner’s findings must be upheld if they are supported by substantial evidence in the record as a whole. 42 U.S.C. § 405(g); Choate v.

Barnhart, 457 F.3d 865, 869 (8th Cir. 2006); Howard, 255 F.3d at 580. The court reviews the Commissioner’s decision to determine if an error of law was committed. Smith v. Sullivan, 982 F.2d 308, 311 (8th Cir. 1992). “Substantial evidence is less than a preponderance, but is enough that a reasonable mind would find it adequate to support the Commissioner’s conclusion.” Cox v. Barnhart, 471 F.3d 902, 906 (8th Cir. 2006) (internal citation and quotation marks omitted). The review of a decision to deny benefits is “more than an examination of

the record for the existence of substantial evidence in support of the Commissioner’s decision . . . [the court must also] take into account whatever in the record fairly detracts from that decision.” Reed v. Barnhart, 399 F.3d 917, 920 (8th Cir. 2005) (quoting Haley v. Massanari, 258 F.3d 742, 747 (8th Cir. 2001)). It is not the role of the court to re-weigh the evidence and, even if this court would decide the case differently, it cannot reverse the Commissioner’s decision if that decision is supported by good reason and is based on

substantial evidence. Guilliams v. Barnhart, 393 F.3d 798, 901 (8th Cir. 2005). A reviewing court may not reverse the Commissioner’s decision “‘merely because substantial evidence would have supported an opposite decision.’” Reed, 399 F.3d at 920 (quoting Shannon v. Chater, 54 F.3d 484, 486 (8th Cir. 1995)). Issues of law are reviewed de novo with deference given to the Commissioner’s construction of the Social Security Act. See Smith, 982 F.2d at 311.

The Social Security Administration established a five-step sequential evaluation process for determining whether an individual is disabled and entitled to benefits under Title XVI. 20 CFR § 416.920(a). If the ALJ determines a claimant is not disabled at any step of the process, the evaluation does not proceed to the next step as the claimant is not disabled. Id. The five- step sequential evaluation process is: (1) Whether the claimant is presently engaged in a “substantial gainful activity”; (2) whether the claimant has a severe impairment – one that significantly limits the claimant’s physical or mental ability to perform basic work activities; (3) whether the claimant has an impairment that meets or equals a presumptively disabling impairment listed in the regulations (if so, the claimant is disabled without regard to age, education, and work experience); (4) whether the claimant has the residual functional capacity to perform . . . past relevant work; and (5) if the claimant cannot perform the past work, the burden shifts to the Commissioner to prove there are other jobs in the national economy the claimant can perform.

Baker v. Apfel, 159 F.3d 1140, 1143–44 (8th Cir. 1998); see also Boyd v. Sullivan, 960 F.2d 733, 735 (8th Cir. 1992) (the criteria under 20 CFR § 416.920 are the same under 20 CFR § 404.1520 for disability insurance benefits). The ALJ applied the five-step sequential evaluation required by the Social Security Administration regulations and found Mr. C. was not disabled. (AR at pp. 23-38). DISCUSSION Mr. C.

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Chauncey v. Saul, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chauncey-v-saul-sdd-2022.