Dowell v. Commissioner of Social Security

CourtDistrict Court, W.D. North Carolina
DecidedJuly 24, 2025
Docket1:24-cv-00123
StatusUnknown

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

Bluebook
Dowell v. Commissioner of Social Security, (W.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA ASHEVILLE DIVISION CIVIL ACTION NO. 1:24-CV-00123-KDB-DCK

DAVID MICHAEL DOWELL,

Plaintiff,

v. ORDER

FRANK BISIGNANO, COMMISSIONER OF SOCIAL SECURITY,

Defendant.

THIS MATTER is before the Court on Plaintiff David Dowell’s appeal of an unfavorable administrative decision denying his application for disability insurance benefits under the Social Security Act (Doc. No. 5); Defendant Commissioner of Social Security’s (“Commissioner”) Response (Doc. No. 6); and the Memorandum and Recommendation (“M&R”) of the Honorable Magistrate David C. Keesler (Doc. No. 8), which recommends that the Commissioner’s decision be affirmed. Having reviewed and considered the parties’ briefs, the administrative record, and the applicable authority, the Court finds the Commissioner’s decision to deny Mr. Dowell Social Security benefits is supported by substantial evidence and uses the correct legal standards. Accordingly, the Court will adopt the M&R and the Commissioner’s decision will be AFFIRMED. I. BACKGROUND No party has objected to the Magistrate Judge’s statement of the factual and procedural background of this case. Therefore, the Court adopts the facts as set forth in the M&R. See Thomas v. Arn, 474 U.S. 140, 149–50 (1985) (explaining the Court is not required to review, under a de novo or any other standard, the factual or legal conclusions of the magistrate judge to which no objections have been raised). II. STANDARD OF REVIEW A. Review of the Commissioner’s Determination Pursuant to the Social Security Act, 42 U.S.C. § 405(g) and § 1383(c)(3), this Court’s

review of a final decision of the Commissioner is limited to: (1) whether substantial evidence supports the Commissioner’s decision, Richardson v. Perales, 402 U.S. 389, 390, 401 (1971); and (2) whether the Commissioner applied the correct legal standards. Hays v. Sullivan, 907 F.2d 1453, 1456 (4th Cir. 1990); see also Hunter v. Sullivan, 993 F.2d 31, 34 (4th Cir. 1992) (per curiam). The District Court does not review a final decision of the Commissioner de novo. Smith v. Schweiker, 795 F.2d 343, 345 (4th Cir. 1986); King v. Califano, 599 F.2d 597, 599 (4th Cir. 1979); Blalock v. Richardson, 483 F.2d 773, 775 (4th Cir. 1972). Indeed, the Act specifically provides that “[t]he findings of the [Commissioner] as to any fact, if supported by substantial evidence, shall be conclusive.” 42 U.S.C. § 405(g). The Fourth

Circuit has explained that “[s]ubstantial evidence has been defined as being more than a scintilla and it must do more than create a suspicion of the existence of a fact to be established. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Smith v. Heckler, 782 F.2d 1176, 1179 (4th Cir. 1986) (quoting Richardson, 402 U.S. at 401); see also Seacrist v. Weinberger, 538 F.2d 1054, 1056–57 (4th Cir. 1976) (“We note that it is the responsibility of the [Commissioner] and not the courts to reconcile inconsistencies in the medical evidence.”). The Fourth Circuit has thus long emphasized that it is not for a reviewing court to weigh the evidence again, nor to substitute its judgment for that of the Commissioner, assuming the Commissioner’s final decision is supported by substantial evidence. Hays, 907 F.2d at 1456; see also Smith, 795 F.2d at 345; Blalock, 483 F.2d at 775. This is true even if the reviewing court disagrees with the outcome—so long as there is “substantial evidence” in the record to support the final decision below. Lester v. Schweiker, 683 F.2d 838, 841 (4th Cir. 1982). B. Review of the Memorandum and Recommendation

A district court may designate a magistrate judge to “submit to a judge of the court proposed findings of fact and recommendations for the disposition” of dispositive pretrial matters, including motions to dismiss. 28 U.S.C. § 636(b)(1). Any party may object to the magistrate judge’s proposed findings and recommendations, and the court “shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1). However, the Court does not perform a de novo review where a party makes only “general and conclusory objections that do not direct the court to a specific error in the magistrate’s proposed findings and recommendations.” Orpiano v. Johnson, 687 F.2d 44, 47 (4th Cir. 1982). After reviewing the record, the court may accept, reject,

or modify, in whole or in part, the findings or recommendations made by the magistrate judge or recommit the matter with instructions. 28 U.S.C. § 636(b)(1). III. DISCUSSION In June 2016, Mr. Dowell filed an application for disability insurance benefits, alleging disability beginning in November 2013. Doc. No. 2-14 at 13. More specifically, he claimed that he was disabled based on his post traumatic stress disorder (“PTSD”) and other ailments that prevented him from working. See generally Doc. No. 5. Upon review of the matter, the Magistrate Judge determined that there was substantial evidence in the record to support the ALJ’s findings that Mr. Dowell was not disabled under the law during the relevant period and recommended affirmance of the Commissioner’s decision to deny benefits. Mr. Dowell timely objects to the M&R, primarily arguing that the Fourth Circuit’s decisions in Rogers and Shelley C should lead to a finding that he is disabled, and that the Magistrate Judge erred in distinguishing his case from those decisions. Doc. No. 9 at 1. A. The ALJ Decision

The ALJ followed the required five-step sequential evaluation process established by the Social Security Administration (“SSA”) to determine whether Mr. Dowell was disabled under the law during the relevant period.1 The ALJ confirmed at step one that Mr. Dowell had not engaged in substantial activity during the period from November 5, 2013, through his date last insured (“DLI”) on June 30, 2015. Doc. No. 2-14 at 16. At step two, the ALJ found that Mr. Dowell had medically determinable impairments that significantly limit his ability to perform basic work activities.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Bonnilyn Mascio v. Carolyn Colvin
780 F.3d 632 (Fourth Circuit, 2015)
Jeffrey Pearson v. Carolyn Colvin
810 F.3d 204 (Fourth Circuit, 2015)
Esin Arakas v. Commissioner, Social Security
983 F.3d 83 (Fourth Circuit, 2020)
Shanette Rogers v. Kilolo Kijakazi
62 F.4th 872 (Fourth Circuit, 2023)

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Dowell v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dowell-v-commissioner-of-social-security-ncwd-2025.