Green v. Commissioner of Social Security

CourtDistrict Court, District of Columbia
DecidedMay 20, 2024
DocketCivil Action No. 2022-0904
StatusPublished

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

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Green v. Commissioner of Social Security, (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

STEPHANIE G., 1

Plaintiff,

v. Case No. 22-cv-00904-RMM

MARTIN O’MALLEY, 2 Commissioner of Social Security,

Defendant.

MEMORANDUM OPINION AND ORDER

Plaintiff Stephanie G. brought this action under a provision of the Social Security Act, 42

U.S.C. § 405(g), seeking review of the Commissioner of Social Security’s decision to deny her

claim for Social Security Disability Insurance and Supplemental Security Income benefits. With

the parties’ consent, the matter was referred to the undersigned for all purposes. See Notice of

Consent, ECF No. 9; Order, ECF No. 16. Now pending are Ms. G.’s Motion for Judgment of

Reversal, ECF No. 11, and the Commissioner’s Motion for Judgment of Affirmance, ECF No.

13. Having reviewed the Administrative Record, 3 the parties’ briefs, 4 and the relevant law, the

Court DENIES Ms. G.’s Motion for Judgment of Reversal.

1 Plaintiff’s name has been partially redacted in keeping with the recommendation of the Committee on Court Administration and Case Management of the Judicial Conference of the United States. See Mem. from Hon. Wm. Terrell Hodges, Chair, Comm. on Ct. Admin. & Case Mgmt., to Chief Judges of the U.S. Cts. of Appeals et al. (May 1, 2018), available at https://www.uscourts.gov/sites/default/files/18-ap-c-suggestion_cacm_0.pdf. 2 Martin O’Malley became Commissioner of Social Security on December 20, 2023. Pursuant to Federal Rule of Civil Procedure 25(d) and the last sentence of 42 U.S.C. § 405(g), Mr. O’Malley is substituted for Kilolo Kijakazi as the Defendant in this case. 3 Page citations to the Administrative Record, ECF No. 6 (“AR”), refer to the running pagination at the lower right margin. 4 The relevant briefs are Ms. G.’s Motion for Judgment of Reversal, ECF No. 11 (“Pl.’s Mem.”); the Commissioner’s Memorandum in Support of his Motion for Judgment of BACKGROUND

Ms. G. applied for Social Security Disability Insurance and Supplemental Security

Income benefits on November 7, 2019, when she was 59 years old. See AR 60–72, 75. Her

disability claim is based on a combination of physical impairments including fibromyalgia,

migraines, spine disorders, and traumatic brain injury. See AR 67. In her application for

benefits, she alleged the following illnesses, injuries, and conditions: concussion; migraines;

myalgia and fibromyalgia; raised antibody titer; neck, shoulder, and back pain; chronic fatigue;

sensitivity to light; and numbness in the right arm. See AR 60–61. Ms. G. claims her disability

began on November 7, 2019. See AR 15.

Ms. G.’s application for benefits was denied at both the initial and reconsideration levels

of review. See AR 1–14. She requested a hearing before an Administrative Law Judge (“ALJ”),

which was held on August 6, 2021. See AR 144. On August 20, 2021, the ALJ denied Ms. G.’s

application for benefits. See AR 15–27. The Appeals Council denied Ms. G.’s request for

review of the ALJ’s decision on March 17, 2022. See AR 1. The ALJ’s decision therefore

constitutes the Commissioner’s final decision, which Ms. G. has asked this Court to reverse, or

alternatively remand for further hearings pursuant to 42 U.S.C. § 405(g). See Pl.’s Mem. at 1.

The Social Security Administration (SSA) filed a cross-motion asking that the Court affirm the

decision. See Def.’s Mem. at 1.

I. Legal Framework

To qualify for benefits under the Social Security Act, a claimant must demonstrate a

disability that renders her unable to “engage in any substantial gainful activity by reason of any

Affirmance and in Opposition to Ms. G.’s Motion, ECF No. 13 (“Def.’s Mem.”); and Ms. G.’s Reply in Support of her Motion and in Opposition to the Commissioner’s Motion, ECF No. 15 (“Pl.’s Reply”).

2 medically determinable physical or mental impairment . . . which has lasted or can be expected to

last for a continuous period of not less than 12 months.” 42 U.S.C. §§ 423(a), 423(d)(1)(A),

1382(a)(1), 1382(a)(3)(A).

The Commissioner uses a five-step process to determine whether a claimant is disabled

under the Act. See 20 C.F.R. §§ 404.1520, 416.920; see also Butler v. Barnhart, 353 F.3d 992,

997 (D.C. Cir. 2004) (describing each step). At step one, the claimant must show she is not

engaged in “substantial gainful activity.” 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4). At step

two, she must show she has a “severe medically determinable physical or mental impairment” or

combination of impairments. Id. § 404.1520(a)(4), 416.920(a)(4). At step three, the

Commissioner must determine whether the claimant’s impairment or impairments meet or equal

an entry in the Commissioner’s Listings maintained at 20 C.F.R. part 404, subpart P, appendix 1.

The Listings describe impairments that the Commissioner considers disabling without regard to a

claimant’s age, education, or work experience. Id. §§ 404.1520(d), 416.920(d). If the claimant’s

impairment is listed, or if her impairments together equal an impairment in the Listings, the

Commissioner will conclude that the individual is disabled and end her inquiry. Id.; see also

Petty v. Colvin, 204 F. Supp. 3d 196, 200 (D.D.C. 2016).

A claimant may still be disabled if her impairments do not meet or equal a Listing. In

that case, the Commissioner must next assess the claimant’s residual functional capacity

(“RFC”). See 20 C.F.R. §§ 404.1520(a)(4), (e), 416.920(a)(4), (e). RFC measures what an

individual “can do in a work setting” despite the person’s physical and mental limitations. Id. §§

404.1545(a)(1), 416.945(a)(1). There are five different categories of RFC: sedentary, light,

medium, heavy, or very heavy work. See generally id. § 404.1567. The definitions and

requirements of these categories are outlined in the relevant statutes. Id. § 404.1567(a)

3 (sedentary work); id. § 404.1567(b) (light work); id. § 404.1567(c) (medium work); id. §

404.1567(d) (heavy work); id. § 404.1567(e) (very heavy work).

The RFC is then used to determine, at step four, whether the claimant’s impairments

prevent her from performing past relevant work, and at step five, whether the claimant can

perform other work that exists in the national economy consistent with the claimant’s age,

education, and work experience. Id. §§ 404.1520(a)(4), 416.920(a)(4); see also Butler, 353 F.3d

at 997. If an individual’s claim fails at either step four or step five, the Commissioner will

conclude that the individual is not disabled and deny the claimant’s benefits request. See 20

C.F.R. §§ 404.1520(a)(4), 416.920(a)(4).

II. Record Evidence

A. Personal Background

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