Crawford v. Kijakazi (CONSENT)

CourtDistrict Court, M.D. Alabama
DecidedDecember 14, 2021
Docket2:20-cv-00024
StatusUnknown

This text of Crawford v. Kijakazi (CONSENT) (Crawford 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
Crawford v. Kijakazi (CONSENT), (M.D. Ala. 2021).

Opinion

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

CARL DOUGLAS CRAWFORD, ) ) Plaintiff, ) ) v. ) CASE NO. 2:20-cv-24-JTA ) (WO) KILOLO KIJAKAZI, ) Acting Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER Pursuant to 42 U.S.C. § 405(g), the claimant, Carl Douglas Crawford, brings this action to review a final decision by the Commissioner of Social Security (“Commissioner”). (Doc. No. 1.)1 The Commissioner denied Crawford’s claim for a period of disability and for disability insurance benefits (“DIB”) (Id.) The parties have consented to the exercise of dispositive jurisdiction by a magistrate judge pursuant to 28 U.S.C. § 636(c). (Docs. No. 7, 8.) After careful scrutiny of the record and the briefs submitted by the parties, the Court finds that the decision of the Commissioner is due to be AFFIRMED.

1 Document numbers, as they appear on the docket sheet, are designated as “Doc. No.” I. PROCEDURAL HISTORY AND FACTS Carl Douglas Crawford (“Crawford”) was born on May 7, 1964 and was 54 years old at the time of the administrative hearing held on December 19, 2018. (R. 30-31, 668.)2

He graduated from college and previously worked in military telecommunications. (R. 16, 32-33.) Crawford alleges a disability onset date of March 31, 2010 (R. 30, 668), due to post-traumatic stress disorder (“PTSD”), traumatic brain injury, sleep apnea, degenerative joint disease of the thoracic spine, right lower extremity peripheral neuropathy (sciatic nerve), light paralysis of the sciatic nerve, obsessive-compulsive disorder, anxiety disorder,

blurry vision, and tinnitus (R. 16, 671).3 Crawford applied for a period of disability and DIB on June 27, 2017 under Title II of the Social Security Act, 42 U.S.C. §§ 401, et seq. (R. 11.) The application was denied on August 18, 2017 (R. 594-95) and Crawford requested an administrative hearing (R. 604).

Following an administrative hearing, the Administrative Law Judge (“ALJ”) denied Crawford’s request for benefits in a decision dated April 25, 2019. (R. 8-20.) The Appeals Council subsequently denied his request for review and the decision by the Commissioner

2 Citations to the administrative record are consistent with the transcript of administrative proceedings filed in this case. (Doc. No. 20.)

3 The ALJ appears to have mistakenly substituted tendinitis for tinnitus as one of the impairments listed in Crawford’s application for disability benefits. (R. 16.) became final.4 (R. 1-4.) On January 10, 2020, Crawford filed the instant action appealing the decision of the Commissioner. (Doc. No. 1.)

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

4 Doughty v. Apfel, 245 F.3d 1274, 1278 (11th Cir. 2001) (“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.”) (citation omitted). 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

the 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. § 404.1572(a).

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