Craft v. Commissioner of the Social Security Administration

CourtDistrict Court, D. South Carolina
DecidedApril 21, 2025
Docket4:24-cv-01642
StatusUnknown

This text of Craft v. Commissioner of the Social Security Administration (Craft v. Commissioner of the Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, D. South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Craft v. Commissioner of the Social Security Administration, (D.S.C. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION KIMBERLY CRAFT, ) Civil Action No.: 4:24-cv-01642-RMG-TER Plaintiff, ) ) -vs- ) ) Report and Recommendation LELAND DUDEK1, ) Acting 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, denying Plaintiff’s claim for disability insurance benefits(DIB). 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 for DIB in October 2020, alleging onset of March 1, 2020. (Tr. 17). Her claims were denied initially and upon reconsideration. Thereafter, Plaintiff filed a request for a hearing. Plaintiff and a VE testified at a hearing in January 2023. (Tr. 17). The Administrative Law Judge (ALJ) issued an unfavorable decision on February 20, 2023, finding that Plaintiff was not disabled within the meaning of the Act. (Tr. 17-31). Plaintiff filed a request for review of the ALJ’s decision, which the Appeals Council denied in February 2024, making the ALJ’s decision the 1Leland Dudek became the Acting Commissioner of Social Security in February 2025. Pursuant to Fed. R. Civ. P. 25(d), he is automatically substituted for Defendant Martin O’Malley who was the Commissioner of Social Security when this action was filed. Commissioner’s final decision. (Tr. 1-3). Plaintiff filed this action in April 2024. (ECF No. 1). B. Introductory Facts Plaintiff was born in July 1992, and was twenty-seven years old on the alleged disability onset date. (Tr. 30). Plaintiff has past relevant work as an assembler. (Tr. 29). Plaintiff alleges

disability initially due to severe manic bipolar, depression, anxiety, and PTSD. (Tr. 95). Pertinent records will be discussed under the relevant issue headings. C. The ALJ’s Decision In the decision of February 20, 2023, the ALJ made the following findings of fact and conclusions of law (Tr. 17-31): 1. The claimant meets the insured status requirements of the Social Security Act through March 31, 2023. 2. The claimant has not engaged in substantial gainful activity since March 1, 2020, the alleged onset date (20 CFR 404.1571 et seq.). 3. The claimant has the following severe impairments: post-traumatic stress disorder (PTSD), anxiety, depression, bipolar disorder, abdominal dysfunction, hematochezia, and obesity (20 CFR 404.1520(c)). 4. The claimant does not have 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 and 404.1526). 5. After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) except she should avoid concentrated exposure to hazards. She can understand and remember simple and detailed instructions. She can attend and perform simple unskilled tasks. She can maintain concentration and attention for periods of at least two hours. The claimant can respond appropriately to supervision, coworkers and usual work situations but would perform best in settings that do not require ongoing frequent interaction with the public. The claimant can be aware of normal hazards and take appropriate precautions, use judgment, and make simple 2 work-related decisions and respond appropriately to changes in a routine work setting. 6. The claimant can perform past relevant work as an assembler. This work does not require the performance of work-related activities precluded by the claimant’s residual functional capacity (20 CFR 404.1565). 7. The claimant has not been under a disability, as defined in the Social Security Act, from March 1, 2020, through the date of this decision (20 CFR 404.1520(f)). II. DISCUSSION Plaintiff argues the ALJ failed to provide adequate reasons for his subjective symptom evaluation and the ALJ based part of the decision on a mistake of fact. (ECF No. 8 at 18-24). Defendant argues that the ALJ’s decision comports with law, was adequately articulated to facilitate judicial review, and satisfies the substantial evidence standard. (ECF No. 9). A. LEGAL FRAMEWORK 1. The Commissioner’s Determination–of–Disability Process The Act provides that disability benefits shall be available to those persons insured for benefits, who are not of retirement age, who properly apply, and who are under a “disability.” 42 U.S.C. § 423(a). Section 423(d)(1)(A) 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 at least 12 consecutive months. 42 U.S.C. § 423(d)(1)(A). To facilitate a uniform and efficient processing of disability claims, regulations promulgated under the Act have reduced the statutory definition of disability to a series of five sequential questions. See, e.g., Heckler v. Campbell, 461 U.S. 458, 460 (1983) (discussing considerations and

3 noting the “need for efficiency” in considering disability claims). An examiner must consider the following: (1) whether the claimant is engaged in substantial gainful activity (“SGA”); (2) whether he has a severe impairment; (3) whether that impairment meets or equals an impairment included in the Listings;2 (4) whether such impairment prevents claimant from performing PRW;3 and (5)

whether the impairment prevents him from doing SGA. See 20 C.F.R. § 404.1520. These considerations are sometimes referred to as the “five steps” of the Commissioner’s disability analysis. If a decision regarding disability may be made at any step, no further inquiry is necessary. 20 C.F.R. § 404.1520(a)(4) (providing that if Commissioner can find claimant disabled or not disabled at a step, Commissioner makes determination and does not go on to the next step). A claimant is not disabled within the meaning of the Act if he can return to PRW as it is customarily performed in the economy or as the claimant actually performed the work. See 20

C.F.R. Subpart P, § 404.1520(a), (b); Social Security Ruling (“SSR”) 82–62 (1982).

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Craft v. Commissioner of the Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/craft-v-commissioner-of-the-social-security-administration-scd-2025.