Finkley v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedAugust 19, 2025
Docket5:24-cv-01258
StatusUnknown

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

Bluebook
Finkley v. Social Security Administration, Commissioner, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA NORTHEASTERN DIVISION

SARA FINKLEY, ) ) Plaintiff, ) ) v. ) ) Case No. 5:24-cv-1258-LCB SOCIAL SECURITY ) ADMINISTRATION, ) COMMISSIONER ) ) Defendant. )

MEMORANDUM OPINION Plaintiff Sara Finkley seeks judicial review of the final decision by the Social Security Administration’s Commissioner to deny her claim for disability benefits. 42 U.S.C. § 405(g). The Court has closely examined the record, and now AFFIRMS the Commissioner’s decision for the reasons explained below. I. BACKGROUND A. Standard of Review A court’s only task in reviewing a denial of disability benefits is to determine whether the Commissioner’s decision is “supported by substantial evidence and based on proper legal standards.” Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011). Substantial evidence “is such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Id. Thus, courts reviewing an appeal from a denial of disability benefits may not “decid[e] the facts anew, mak[e] credibility determinations, or re-weigh[ ] the

evidence.” Moore v. Barnhart, 405 F.3d 1208, 1211 (11th Cir. 2005). Rather, the court must affirm the Commissioner’s decision if the denial is supported by substantial evidence, even if the preponderance of the evidence weighs against the

Commissioner’s findings. Henry v. Comm’r of Soc. Sec., 802 F.3d 1264 (11th Cir. 2015); Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983). B. Procedural History Finkley first applied for disability insurance benefits on May 24, 2022, Tr. 10,

alleging disabilities consisting of fibromyalgia, degenerative disc disease, hypertension, generalized anxiety disorder, migraine headaches, major depressive disorder, asthma, and “whiplash in neck.” Id. at 265. At the time of her application,

Finkley reported being 4’11” and 189 pounds. Id. Finkley’s claim was initially denied on January 20, 2023, id. at 124, and denied again after reconsideration on September 25, 2023. Id. at 133. Finkley requested a hearing by an ALJ on September 29, id. at 152-53, and the ALJ held a

hearing on April 10, 2024. Id. at 41-58. Finkley was represented by counsel at that hearing, which also included testimony from an impartial Vocational Expert. Id. On May 16, 2024, the ALJ again denied Finkley’s claim, id. at 7, and the

ALJ’s unfavorable decision became final after the Social Security Appeals Council denied review on July 18, 2024. Id. at 2. Having exhausted her administrative remedies, Finkley appealed the Commissioner’s final decision in this Court on

September 15, 2024. Doc. 1. C. The Social Security Disability Framework The Social Security disability framework requires an ALJ to ask a series of questions to determine whether an applicant qualifies for disability benefits:

(1) Is the claimant engaged in substantial gainful activity? (2) Does the claimant have a severe impairment? (3) Does the claimant have an impairment or combination of impairments that meet or medically equal an impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1? (4) Is the claimant able to perform former relevant work? (5) Is the claimant able to perform any other work within the national economy?1 20 C.F.R. §§ 404.1520(a), 416.920(a); McDaniel v. Bowen, 800 F.2d 1026, 1030 (11th Cir. 1986). These steps are progressive, and the inquiry ends if the ALJ finds that the claimant has not met the requirements of any individual step. As a result, an ALJ will reach Step 4 only if a claimant is not engaged in substantial gainful activity (Step 1), has a severe impairment (Step 2), and does not have an impairment or combination of impairments that meets or medically equals a listed impairment (Step

1 A claimant bears the burden of proof through Step 4, but the burden shifts to the Commissioner at Step Five. See Wolf v. Chater 86 F.3d 1072, 1077 (11th Cir. 1996). 3). McDaniel v. Bowen, 800 F.2d 1026, 1030 (11th Cir. 1986). Then, between Step 3 and Step 4, the ALJ must determine the claimant’s residual function capacity

(“RFC”), which is the claimant’s ability to perform work of any kind despite “all . . . medically determinable impairments” of which the ALJ is aware, “including . . . medically determinable impairments that are not ‘severe.’” 20 C.F.R.

§ 404.1545(a)(2). Once the claimant’s RFC is established, the ALJ compares the claimant’s RFC to the demands of their former relevant work (Step 4) and any other work in the national economy (Step 5). If a claimant can perform former relevant work, or

the Agency can show that the claimant is able to perform any other work in the national economy, then the claimant is not disabled. 20 C.F.R. §§ 404.1512(f), (g). D. The ALJ’s Analysis

The ALJ’s opinion followed the required analysis to the letter. See Tr. 12-23. At Step 1, the ALJ found that Finkley had not engaged in substantial gainful activity since May 11, 2022. Tr. 12. At Step 2, the ALJ found that Finkley suffers from multiple severe

impairments, namely “obesity, cervical and lumbar degenerative disc disease, hypertension, depression, and anxiety.” Id. at 13 (citing 20 CFR 404.1520(c); 416.920(c)). The ALJ also found that Finkley suffers from non-severe impairments, including “asthma, allergies, obstructive sleep apnea, sciatica, migraine headaches, carpal tunnel syndrome, and eczema.” Id. at 13.

At Step 3, the ALJ found that none of Finkley’s impairments met or medically equaled the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1. Id. at 13.

After Step 3, following “careful consideration of the entire record,” the ALJ concluded that Finkley possessed the RFC to perform “light work,” with some additional limitations. Id. at 20. The ALJ found that Finkley can “occasionally balance . . . stoop, kneel, crouch, and crawl; tolerate occasional exposure to

occupational atmospheric conditions such as dust, fumes, odors, and pulmonary irritants.” Id. at 16. As for limitations, the ALJ found that Finkley should “never climb ladders/scaffolds and [only] occasionally climb ramps/stairs,” that Finkley

should “never work around hazards including unprotected moving mechanical parts or unprotected heights,” and that Finkley “can only perform simple tasks” and is “limited to occasional interaction with the public and coworkers in work situations.” Id.

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