Groves v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedAugust 29, 2023
Docket3:22-cv-00887
StatusUnknown

This text of Groves v. Social Security Administration, Commissioner (Groves 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
Groves v. Social Security Administration, Commissioner, (N.D. Ala. 2023).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA NORTHWESTERN DIVISION

BRIAN D. GROVES, ) ) Plaintiff, ) ) vs. ) Case No. 3:22-cv-00887-HNJ ) SOCIAL SECURITYADMINISTRATION, ) COMMISSIONER, ) ) Defendant. )

MEMORANDUM OPINION

Plaintiff Brian Groves seeks judicial review pursuant to 42 U.S.C. § 405(g) of an adverse, final decision of the Commissioner of the Social Security Administration (“Commissioner”), regarding his claim for supplemental security income benefits.1 The undersigned carefully considered the record, and for the reasons expressed herein, the court REVERSES the Commissioner’s decision and REMANDS for further consideration of the functional impairments resulting from Groves’s lumbar condition, and for the ALJ to gather additional medical evidence regarding the extent of Groves’s limitations, either from a consultative medical examiner or from Groves’s treating

1 Groves also filed an application for disability insurance benefits. However, during the administrative hearing, Groves’s representative amended the alleged onset date to June 19, 2020, as the Commissioner had denied Groves’s prior applications in 2009 and 2013, thereby precluding arguments for disability prior to those dates, and Groves possessed no evidence of disability prior to December 31, 2000, the latest date Groves enjoyed insured status due to his previous employment. For the same reasons, the ALJ stated the claim would proceed forward only as to Groves’s SSI benefits. (Tr. 34- 37). providers.2 LAW AND STANDARD OF REVIEW

To qualify for benefits, the claimant must be disabled as defined by the Social Security Act and the Regulations promulgated thereunder. The Regulations define “disabled” 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.” 20 C.F.R. § 416.905(a). To establish an entitlement to disability benefits, a claimant must provide evidence of a “physical or mental impairment” which “results from anatomical, physiological, or psychological abnormalities which are

demonstrable by medically acceptable clinical and laboratory diagnostic techniques.” 42 U.S.C. § 423(d)(3). In determining whether a claimant suffers a disability, the Commissioner, through an Administrative Law Judge (ALJ), works through a five-step sequential

evaluation process. See 20 C.F.R. § 416.920(a)(4). The burden rests upon the claimant at the first four steps of this five-step process; the Commissioner sustains the burden at step five, if the evaluation proceeds that far. Washington v. Comm’r of Soc. Sec., 906 F.3d 1353, 1359 (11th Cir. 2018).

2 In accordance with the provisions of 28 U.S.C. § 636(c) and Federal Rule of Civil Procedure 73, the parties have voluntarily consented to have a United States Magistrate Judge conduct any and all proceedings, including the entry of final judgment. (Doc. 10). In the first step, the claimant cannot be currently engaged in substantial gainful activity. 20 C.F.R. § 416.920(b). Second, the claimant must prove the impairment is

“severe” in that it “significantly limits [the] physical or mental ability to do basic work activities . . . .” Id. at § 416.920(c). At step three, the evaluator must conclude the claimant is disabled if the impairments meet or medically equal one of the impairments listed at 20 C.F.R. Part

404, Subpart P, App. 1, §§ 1.00-114.02. Id. at § 416.920(d). If a claimant’s impairment meets the applicable criteria at this step, that claimant’s impairment would prevent any person from performing substantial gainful activity. 20 C.F.R. §§ 416.920(a)(4)(iii), 416.925. That is, a claimant who satisfies steps one and two qualifies automatically for

disability benefits if the claimant suffers a listed impairment. See Williams v. Astrue, 416 F. App’x 861, 862 (11th Cir. 2011) (“If, at the third step, [the claimant] proves that [an] impairment or combination of impairments meets or equals a listed impairment, [the claimant] is automatically found disabled regardless of age, education, or work

experience.”) (citing 20 C.F.R. § 416.920; Crayton v. Callahan, 120 F.3d 1217, 1219 (11th Cir. 1997)). If the claimant’s impairment or combination of impairments does not meet or

medically equal a listed impairment, the evaluation proceeds to the fourth step, where the claimant demonstrates an incapacity to meet the physical and mental demands of past relevant work. 20 C.F.R. § 416.920(e). At this step, the evaluator must determine whether the claimant has the residual functional capacity (“RFC”) to perform the requirements of past relevant work. See id. § 416.920(a)(4)(iv). If the claimant’s impairment or combination of impairments does not prevent performance of past

relevant work, the evaluator will determine the claimant is not disabled. See id. If the claimant succeeds at the preceding step, the fifth step shifts the burden to the Commissioner to provide evidence, considering the claimant’s RFC, age, education and past work experience, that the claimant is capable of performing other work. 20

C.F.R. §§ 416.912(b)(3), 416.920(g). If the claimant can perform other work, the evaluator will not find the claimant disabled. See id. § 416.920(a)(4)(v); see also 20 C.F.R. § 416.920(g). If the claimant cannot perform other work, the evaluator will find the claimant disabled. 20 C.F.R. §§ 416.920(a)(4)(v), 416.920(g).

The court must determine whether substantial evidence supports the Commissioner’s decision and whether the Commissioner applied the proper legal standards. Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011). The court reviews the ALJ’s “‘decision with deference to the factual findings and close scrutiny of

the legal conclusions.’” Parks ex rel. D.P. v. Comm’r, Social Sec. Admin., 783 F.3d 847, 850 (11th Cir. 2015) (quoting Cornelius v. Sullivan, 936 F.2d 1143, 1145 (11th Cir. 1991)). Indeed, “an ALJ’s factual findings . . . ‘shall be conclusive’ if supported by ‘substantial

evidence.’” Biestek v. Berryhill, 139 S. Ct. 1148, 1153 (2019) (citing 42 U.S.C. § 405(g)). Although the court must “scrutinize the record as a whole . . . to determine if the decision reached is reasonable . . .

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Tina L. Freeman v. Michael J. Astrue
220 F. App'x 957 (Eleventh Circuit, 2007)
Dorothy Couch v. Michael J. Astrue
267 F. App'x 853 (Eleventh Circuit, 2008)
Castel v. Commissioner of Social Security
355 F. App'x 260 (Eleventh Circuit, 2009)
Crayton v. Callahan
120 F.3d 1217 (Eleventh Circuit, 1997)
Andrew T. Wilson v. Jo Anne B. Barnhart
284 F.3d 1219 (Eleventh Circuit, 2002)
Ellison v. Barnhart
355 F.3d 1272 (Eleventh Circuit, 2003)
Billy D. Crawford v. Comm. of Social Security
363 F.3d 1155 (Eleventh Circuit, 2004)
Bobby Dyer v. Jo Anne B. Barnhart
395 F.3d 1206 (Eleventh Circuit, 2005)
Christi L. Moore v. Jo Anne B. Barnhart
405 F.3d 1208 (Eleventh Circuit, 2005)
Ingram v. Commissioner of Social Security Administration
496 F.3d 1253 (Eleventh Circuit, 2007)
Winschel v. Commissioner of Social Security
631 F.3d 1176 (Eleventh Circuit, 2011)
Annette Keaton Williams v. Michael J. Asture
416 F. App'x 861 (Eleventh Circuit, 2011)
Werner v. Commissioner of Social Security
421 F. App'x 935 (Eleventh Circuit, 2011)
Lauri J. Forrester v. Commissioner of Social Security
455 F. App'x 899 (Eleventh Circuit, 2012)

Cite This Page — Counsel Stack

Bluebook (online)
Groves v. Social Security Administration, Commissioner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/groves-v-social-security-administration-commissioner-alnd-2023.