Duff v. Commissioner of Social Security Administration

CourtDistrict Court, W.D. Virginia
DecidedMarch 25, 2022
Docket7:20-cv-00736
StatusUnknown

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

Bluebook
Duff v. Commissioner of Social Security Administration, (W.D. Va. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF VIRGINIA ROANOKE DIVISION

RAINELLE D.,1 ) ) Plaintiff, ) ) v. ) Civil Action No. 7:20-cv-736 ) COMMISSIONER OF SOCIAL SECURITY ) ADMINISTRATION, ) ) Defendant. )

MEMORANDUM OPINION Plaintiff Rainelle D. (“Rainelle”) filed this action challenging the final decision of the Commissioner of Social Security (“Commissioner”) finding her not disabled and therefore ineligible for supplemental security income (“SSI”) under the Social Security Act (“Act”). 42 U.S.C. §§ 1381-1383f. Rainelle argues that the Administrative Law Judge (“ALJ”) erred by failing to properly determine her residual functional capacity (“RFC”). I conclude that the ALJ’s decision is supported by substantial evidence. Accordingly, I GRANT the Commissioner’s Motion for Summary Judgment. Dkt. 21. STANDARD OF REVIEW This court limits its review to a determination of whether substantial evidence supports the Commissioner’s conclusion that Rainelle failed to demonstrate that she was disabled under the Act.2 Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001). This standard of review requires

1 Due to privacy concerns, I use only the first name and last initial of the claimant in social security opinions.

2 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). Disability under the Act requires showing more than the fact that the claimant suffers from an impairment which affects his the Court to “look[] to an existing administrative record and ask[] whether it contains ‘sufficien[t] evidence’ to support the [ALJ’s] factual determinations.” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (quoting Consol. Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). “Substantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion; it consists of more than a mere scintilla of evidence but may be somewhat

less than a preponderance.” Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996) (internal citations omitted). “The threshold for such evidentiary sufficiency is not high,” Biestek, 139 S. Ct. at 1154, and the final decision of the Commissioner will be affirmed where substantial evidence supports the decision. Hays v. Sullivan, 907 F.2d 1453, 1456 (4th Cir. 1990). CLAIM HISTORY Rainelle filed for SSI on October 2, 2014, alleging disability beginning on September 14, 2013, due to her back and leg problems, anxiety, and depression. R. 435, 451. The state agency denied Rainelle’s application at the initial level of administrative review on February 11, 2015, and at the reconsideration level of review on April 10, 2015. R. 158–168, 170–180. On May 19,

2017, ALJ Jeffrey Schueler held a hearing to consider Rainelle’s claim. R. 109–52. Counsel represented Rainelle at the 2017 hearing, which included testimony from vocational expert Ricky Bradley. Id. On July 6, 2017, the ALJ entered his decision denying the claim for SSI benefits. R. 184–97. The ALJ found that Rainelle had the severe physical impairments of osteoarthritis of the hips and degenerative disc disease of the lumbar spine. R. 186. The ALJ also concluded that Rainelle retained the RFC to perform sedentary work with certain limitations and could perform jobs that exist in significant numbers in the national economy, such as an information clerk and

ability to perform daily activities or certain forms of work. Rather, a claimant must show that his impairments prevent him from engaging in all forms of substantial gainful employment given his age, education, and work experience. See 42 U.S.C. §§ 423(d)(2), 1382c(a)(3)(B). telephone solicitor. R. 190, 196. The Appeals Council remanded the case on August 30, 2018 and directed the ALJ to obtain evidence from a vocational expert to clarify the effect of the assessed limitations on the occupational base. R. 15, 203–206. On April 21, 2020, ALJ Michael Dennard held a second hearing by telephone to consider Rainelle’s claim. R. 41–73. Counsel represented Rainelle at the hearing, which included

testimony from vocational expert Kristin Panella. Id. On May 5, 2020, the ALJ entered his decision analyzing Rainelle’s claim under the familiar five-step process3 and denying her claim for SSI benefits. R. 15–32. The relevant period for Rainelle’s SSI claim is from her October 2, 2014 application date through the ALJ’s decision on May 5, 2020. See 20 C.F.R. § 416.202 (explaining that a claimant is not eligible for SSI until, among other factors, the date he files an application for SSI benefits); 20 C.F.R. § 416.501 (stating that a claimant may not be paid SSI for any period that precedes the first month she satisfies the eligibility requirements, which cannot pre-date the date on which an application was filed). The ALJ found that Rainelle had not engaged in substantial gainful activity since October 2, 2014, the application date.4 R. 17. The ALJ determined that Rainelle suffered from severe

impairments of left hip osteoarthritis, status post replacement; right hip osteoarthritis, status post replacement; lumbar degenerative disc disease; bilateral knee osteoarthritis; and obesity. R. 17–

3 The five-step process to evaluate a disability claim requires the Commissioner to ask, in sequence, whether the claimant: (1) is working; (2) has a severe impairment; (3) has an impairment that meets or equals the requirements of a listed impairment; (4) can return to her past relevant work; and if not, (5) whether she can perform other work. Johnson v. Barnhart, 434 F.3d 650, 654 n.1 (4th Cir. 2005) (per curiam) (citing 20 C.F.R.§ 404.1520); Heckler v. Campbell, 461 U.S. 458, 460–62 (1983). The inquiry ceases if the Commissioner finds the claimant disabled at any step of the process. 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4). The claimant bears the burden of proof at steps one through four to establish a prima facie case for disability. At the fifth step, the burden shifts to the Commissioner to establish that the claimant maintains the residual functional capacity (“RFC”), considering the Claimant’s age, education, work experience, and impairments, to perform available alternative work in the local and national economies. 42 U.S.C.

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Duff v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/duff-v-commissioner-of-social-security-administration-vawd-2022.