Coleman v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedJune 5, 2025
Docket2:24-cv-00917
StatusUnknown

This text of Coleman v. Social Security Administration, Commissioner (Coleman 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
Coleman v. Social Security Administration, Commissioner, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

RANISHIA R. COLEMAN, ) ) Plaintiff, ) ) v. ) Case No.: 2:24-cv-00917-AMM ) SOCIAL SECURITY ) ADMINISTRATION, ) Commissioner, ) ) Defendant. )

MEMORANDUM OF DECISION Plaintiff Ranishia R. Coleman brings this action pursuant to the Social Security Act (the “Act”), seeking review of the decision of the Commissioner of Social Security (“Commissioner”) denying her claim for a period of disability and disability insurance benefits (“benefits”). See 42 U.S.C. § 405(g). Based on the court’s review of the record, the court AFFIRMS the decision of the Commissioner. I. Introduction On May 12, 2021, Ms. Coleman protectively filed an application for benefits under Title II of the Act, alleging disability as of June 8, 2020. R. 56, 107–14. Ms. Coleman alleges disability due to multilevel disc desiccation and low back pain. R. 107. The Social Security Administration (“SSA”) initially denied Ms. Coleman’s application on January 14, 2022, and again upon reconsideration on June 3, 2022. R.

56, 107–26. On June 3, 2022, Ms. Coleman filed a request for a hearing before an Administrative Law Judge (“ALJ”). R. 56, 146–48. That request was granted. R. 178–80. Ms. Coleman received a telephone hearing before ALJ Monica D. Jackson

on November 10, 2022. R. 56, 74–106. On May 26, 2023, ALJ Jackson issued a decision, finding that Ms. Coleman was not disabled from June 8, 2020, through the date of decision. R. 53–67. Ms. Coleman appealed to the Appeals Council, which denied her request for

review on September 6, 2023. R. 25–28. After the Appeals Council denied Ms. Coleman’s request for review, R. 25–28, the ALJ’s decision became the final decision of the Commissioner and subject to district court review. On November 3,

2023, Ms. Coleman, proceeding pro se, sought state court review of the ALJ’s decision. See Doc. 1-1. On July 11, 2024, the Commissioner filed a Notice of Removal in this court. See Doc. 1. II. The ALJ’s Decision

The Act establishes a five-step test for the ALJ to determine disability. 20 C.F.R. § 404.1520. First, the ALJ must determine whether the claimant is engaging in substantial gainful activity. 20 C.F.R. § 404.1520(a)(4)(i). “Substantial work

activity is work activity that involves doing significant physical or mental activities.” 20 C.F.R. § 404.1572(a). “Gainful work activity” is work that is done “for pay or profit.” 20 C.F.R. § 404.1572(b). If the ALJ finds that the claimant engages in

substantial gainful activity, then the claimant cannot claim disability. 20 C.F.R. § 404.1520(b). Second, the ALJ must determine whether the claimant has a medically determinable impairment or a combination of medical impairments that significantly

limits the claimant’s ability to perform basic work activities. 20 C.F.R. § 404.1520(a)(4)(ii), (c). Absent such impairment, the claimant may not claim disability. 20 C.F.R. § 404.1520(a)(4)(ii), (c). Third, the ALJ must determine whether the claimant’s impairment meets or medically equals the criteria of an

impairment listed in 20 C.F.R. § 404, Subpart P, Appendix 1. See 20 C.F.R. §§ 404.1520(a)(4)(iii), 404.1520(d), 404.1525, 404.1526. If such criteria are met, the claimant is declared disabled. 20 C.F.R. § 404.1520(a)(4)(iii).

If the claimant does not fulfill the requirements necessary to be declared disabled under the third step, the ALJ still may find disability under the next two steps of the analysis. The ALJ must first determine the claimant’s residual functional capacity, which refers to the claimant’s ability to work despite her impairments. 20

C.F.R. §§ 404.1520(e), 404.1545. In the fourth step, the ALJ determines whether the claimant has the residual functional capacity to perform past relevant work. 20 C.F.R. § 404.1520(a)(4)(iv). If the ALJ determines that the claimant is capable of

performing past relevant work, then the claimant is deemed not disabled. 20 C.F.R. § 404.1520(a)(4)(iv). If the ALJ finds the claimant unable to perform past relevant work, then the analysis proceeds to the fifth and final step. 20 C.F.R. §

404.1520(a)(4)(v). In this step, the ALJ must determine whether the claimant is able to perform any other work commensurate with her residual functional capacity, age, education, and work experience. 20 C.F.R. § 404.1520(g)(1). Here, the burden of

proof shifts from the claimant to the Commissioner to prove the existence, in significant numbers, of jobs in the national economy that the claimant can do given her residual functional capacity, age, education, and work experience. 20 C.F.R. §§ 404.1520(g)(1), 404.1560(c).

The ALJ determined that Ms. Coleman would meet the insured status requirements of the Act through December 31, 2025. R. 57, 58. Next, the ALJ found that Ms. Coleman “has not engaged in substantial gainful activity since June 8, 2020,

the alleged onset date.” R. 59. The ALJ decided that Ms. Coleman had the following severe impairments: depressive disorder with anxiety, cannabis use disorder, obesity, and mild disc desiccation. R. 59. The ALJ decided that Ms. Coleman had the following non-severe impairments: benign intracranial hypertension and

headaches. R. 59. Overall, the ALJ determined that Ms. Coleman “does not have an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments” to support a finding of disability. R. 59. The ALJ found that Ms. Coleman “has the residual functional capacity to perform light work” with certain limitations. R. 61. The ALJ determined that Ms.

Coleman can “understand, remember, and carry out simple instructions and make simple work-related decisions”; and “frequently balance, stoop, kneel, crouch, crawl, and climb ramps and stairs.” R. 61. The ALJ determined that Ms. Coleman

“can never climb ladders, ropes, or scaffolds.” R. 61. The ALJ determined that Ms. Coleman’s past relevant work was that of a cleaner-hospital, assembler, fast food worker, and machine operator. R. 66. Based on the testimony of the vocational expert, the ALJ determined Ms. Coleman “is able

to perform [past relevant work] as actually or generally performed.” R. 66. Based on these findings, the ALJ concluded that Ms. Coleman has not been under a disability as defined in the Act, from June 8, 2020, through the date of

decision. R. 67. Ms.

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