Edwards v. O'Malley (CONSENT)

CourtDistrict Court, M.D. Alabama
DecidedAugust 27, 2025
Docket1:24-cv-00272
StatusUnknown

This text of Edwards v. O'Malley (CONSENT) (Edwards v. O'Malley (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
Edwards v. O'Malley (CONSENT), (M.D. Ala. 2025).

Opinion

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

JAVAUGHN E., ) ) Plaintiff, ) ) v. ) CASE NO. 1:24-cv-272-JTA ) (WO) FRANK BISIGNANO,1 Commissioner ) of Social Security, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER Pursuant to 42 U.S.C. § 405(g), Plaintiff Javaughn E. brings this action to review a final decision by the Commissioner of Social Security (“Commissioner”). (Doc. No. 1.)2 The Commissioner denied Plaintiff’s claim for a Period of Disability and Disability Insurance Benefits (“DIB”). The Court construes Plaintiff’s brief in support of his Complaint (Doc. No. 7) as a motion for summary judgment and the Commissioner’s brief in opposition to the Complaint (Doc. No. 8) as a motion for summary judgment. The parties have consented to the exercise of dispositive jurisdiction by a magistrate judge pursuant to 28 U.S.C. § 636(c). (Docs. No. 10, 11.)

1 Frank Bisignano became the Commissioner of Social Security on May 6, 2025, and under Federal Rule of Civil Procedure 25(d) is automatically substituted as the defendant. See Fed. R. Civ. P. 25(d).

2 Document numbers as they appear on the docket sheet are designated as “Doc. No.” After careful scrutiny of the record and the motions submitted by the parties, the Court finds that Plaintiff’s motion for summary judgment is due to be DENIED, the

Commissioner’s motion for summary judgment is due to be GRANTED, and the decision of the Commissioner is due to be AFFIRMED. I. PROCEDURAL HISTORY AND FACTS Plaintiff is an adult male3 with at least a high school education and prior work experience as a corrections officer, food inspector, phone and equipment salesperson, and security guard. (R. 19.)4 He alleged a disability onset date of January 23, 2023, due to

idiopathic scoliosis, delusional disorder, schizophrenia, post-traumatic stress disorder (“PTSD”), major depressive disorder, perineural cyst, lumbosacral strain, migraine, and tendinitis. (R. 10, 217.) On January 26, 2023, Plaintiff protectively filed a Title II (42 U.S.C. §§ 401, et seq.) application for a period of disability and disability insurance benefits. (R. 10, 67.)

Plaintiff’s claim was denied initially and upon reconsideration. (R. 10, 76, 88.) Plaintiff requested an administrative hearing on August 22, 2023. (R. 106.) Following an administrative hearing, the Administrative Law Judge (“ALJ”) denied Plaintiff’s request for a period of disability and DIB in a decision dated February 26, 2024. (R. 10–21.) Plaintiff requested review by the Appeals Council, and it denied review. (R. 1–6.)

Consequently, the hearing decision became the final decision of the Commissioner. See 42

3 Plaintiff was 36 years old at the alleged disability onset date. (R. 68.)

4 Citations to the administrative record are consistent with the transcript of administrative proceedings filed in this case. (See Doc. No. 6.) U.S.C. § 405(g); Doughty v. Apfel, 245 F.3d 1274, 1278 (11th Cir. 2001) (citation omitted) (“When as in this case, the ALJ denies benefits and the [Appeals Council] denies review,

[the court] reviews[s] the ALJ’s decision as the Commissioner’s final decision.”). On May 3, 2024, Plaintiff filed this action seeking review of the Commissioner’s final decision. (Doc. No. 1.) The parties have briefed their respective positions. (Docs. No. 7, 8, 9.) This matter is ripe for review.

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 court “must scrutinize the record as a whole to determine if the decision reached is reasonable and supported by substantial evidence.” Schink v. Comm’r of Soc. Sec., 935

F.3d 1245, 1257 (11th Cir. 2019) (citations omitted). “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 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 DIB must prove that he is

disabled. See 20 C.F.R. § 404.1505. The Act defines “disability” as the “inability to do 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. § 405.1505(a).

Disability under the Act is determined under a five-step sequential evaluation process. 20 C.F.R.

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Edwards v. O'Malley (CONSENT), Counsel Stack Legal Research, https://law.counselstack.com/opinion/edwards-v-omalley-consent-almd-2025.