CROUSE, JR. v. SSA

CourtDistrict Court, M.D. North Carolina
DecidedAugust 26, 2019
Docket1:18-cv-00269
StatusUnknown

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

Bluebook
CROUSE, JR. v. SSA, (M.D.N.C. 2019).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

WILLIAM MONROE CROUSE, JR. ) ) . Plaintiff, ) ) : Vv. ) 1:18CV269 ) . ANDREW SAUL, . ) Commissioner of Social Secutity,! ) Defendant. )

MEMORANDUM OPINION AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE Plaintiff William Monroe Crouse, Jr. (“Plaintiff’?) brought this action pursuant to Section 1631(c)(3) of the Social Security Act (the “Act’), as amended (42 U.S.C. § 1383(c)(3)), to obtain judicial review of a final decision of the Commissioner of Social Security denying his claim for Supplemental Security Income (“SSI”) under Title XVI of the Act. The parties have filed cross-motions for judgment, and the administrative record has been certified to the Court for review. I PROCEDURAL HISTORY Plaintiff protectively filed an application for SSI on July 31, 2014, alleging a disability onset date of May 1, 2011. (Ir. at 15, 187-195.)? His application was denied initially (T'r. at 102-105) and upon reconsideration (Ir. at 111-115). Thereafter, Plaintiff requested an

1 Andrew Saul became Commissioner of Social Security on June 17, 2019. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Andrew Saul should be substituted for Nancy A. Berryhill as the Defendant in this suit. 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). * Transcript citations refer to the Sealed Administrative Record [Doc. #8].

administrative heating de novo before an Administrative Law Judge (“ALJ”). (Tr. at 116-118.) Plaintiff, along with his attorney and an impattial vocational expert (“VE”), attended the subsequent heating on January 9, 2017. (It. at 30.) The ALJ ultimately concluded that Plaintiff

was not disabled within the meaning of the Act since July 31, 2014, the date the application was filed.3 (Tt. at 25.) On February 6, 2018, the Appeals Council denied Plaintiff's request fot review of the decision, thereby making the ALJ’s conclusion the Commissionet’s final decision for purposes of judicial review. (Tr. at 1-5.) _ Il. LEGALSTANDARD Federal law “authorizes judicial review of the Social Secutity Commissionet’s denial of social security benefits.” Hines v. Barnhart, 453 F.3d 559, 561 (4th Cir. 2006). However, the

scope of review of such a decision is “extremely limited.” Frady v. Harris, 646 F.2d 143, 144 (4th Cit. 1981). “The courts are not to try the case de novo.” Oppenheim v. Finch, 495 F.2d 396, 397 (4th Cir. 1974). Instead, “a reviewing court must uphold the factual findings of the AL] if they ate supported by substantial evidence and were reached through application of the

cottect legal standard.” Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012) (internal quotation omitted). .

“Substantial evidence means ‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Hunter v. Sullivan, 993 F.2d 31, 34 (4th Cir. 1993) (quoting Richardson v. Perales, 402 U.S. 389, 390 (1971)). “It consists of more than a mere scintilla of evidence but may be somewhat less than a preponderance.” Mastro v. Apfel, 270

3 The ruling could not extend to earlier than the application date because SSI is not payable prior to the month following the month in which the application was filed, irrespective of the claimant's alleged onset date. See 20 C.F.R. § 416.335.

F.3d 171, 176 (4th Cir. 2001) (internal citations and quotation marks omitted). “If there is evidence to justify a refusal to direct a verdict were the case before a jury, then there is substantial evidence.” Hunter, 993 F.2d at 34 (internal quotation marks omitted). “In reviewing for substantial evidence, the court should not undertake to re-weigh conflicting evidence, make credibility determinations, or substitute its judgment for that of the [AL]].” Mastro, 270 F.3d at 176 (internal brackets and quotation marks omitted). “Whete conflicting evidence allows reasonable minds to differ as to whether a claimant is disabled, the responsibility for that decision falls on the ALJ.” Hancock, 667 F.3d at 472. “The issue before [the reviewing court], therefote, is not whether [the claimant] is disabled, but whether the AL}’s finding that [the claimant] is not disabled is supported by substantial evidence and was reached based upon a cortect application of the relevant law.” Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996). In undertaking this limited review, the Court notes that “[a] claimant for disability benefits bears the burden of proving a disability.” Hall v. Harris, 658 F.2d 260, 264 (4th Cir. 1981). In this context, “disability” means the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to tesult in death or which has lasted or can be expected to last for a continuous petiod of not less than 12 months.” Id. (quoting 42 U.S.C. § 423()(1)(A)). “The Commissioner uses a five-step ptocess to evaluate disability claims.” Hancock, 667 F.3d at 472 (citing 20 C.F.R. §§ 404.1520(a)(4); 416.920(a)(4)). “Under this process, the Commissioner asks, in sequence, whether the claimant: (1) worked during the alleged period of disability; (2) had a severe impaitment; (3) had an impairment that met or equaled the

requitements of a listed impaitment; (4) could return to her past relevant work; and (5) if not, could perform any othet work in the national economy.” Id. A finding adverse to the claimant at any of several points in this five-step sequence forecloses a disability designation and ends the inquiry. For example, “[t]he first step determines whether the claimant is engaged in ‘substantial gainful activity.’ If the claimant is working, benefits are denied. The second step determines if the claimant is ‘severely’ disabled. If not, benefits are denied.” Bennett v. Sullivan, 917 F.2d 157, 159 4th Cir. 1990). On the other hand, if a claimant carries his or her burden at the first two steps, and if the claimant’s impaitment meets ot equals a “listed impairment” at step three, “the claimant is disabled.” Mastro, 270 F.3d at 177.

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Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
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Jeffrey Pearson v. Carolyn Colvin
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Darren Lamear v. Nancy Berryhill
865 F.3d 1201 (Ninth Circuit, 2017)
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Hancock v. Astrue
667 F.3d 470 (Fourth Circuit, 2012)

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