HAIRSTON v. KIJAKAZI

CourtDistrict Court, M.D. North Carolina
DecidedAugust 24, 2021
Docket1:20-cv-00228
StatusUnknown

This text of HAIRSTON v. KIJAKAZI (HAIRSTON v. KIJAKAZI) is published on Counsel Stack Legal Research, covering District Court, M.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
HAIRSTON v. KIJAKAZI, (M.D.N.C. 2021).

Opinion

IN THE UNITED STATES DISTRIC# COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA

APRYLL MARIE HAIRSTON, ) ) Plaintiff, ) ) v. ) 1:20CV228 ) KILOLO KIJAKAZI,! ) Acting Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM OPINION AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE Plaintiff Apryll Marie Hairston (“Plaintiff”) brought this action pursuant to Section 1631(c)(3) of the Social Security Act (the “Act”), as amended (42 U.S.C. § 1383(c)(3)), to obtain judicial review of a final decision of the Commissioner of Social Security denying her claim fot Supplemental Security Income (“SSI”) under Title XVI of the Act. The parties have filed ctoss-motions fot judgment, and the administrative record has been certified to the Court for review. I. PROCEDURAL HISTORY Plaintiff protectively filed an application for SSI on July 27, 2016, alleging a disability onset date of July 2, 2016. (Tr. at 12, 209-19.)? Her application was denied initially (Tr. at 69-

Kilolo Kijakazi became the Acting Commissioner of Social Security on July 9, 2021. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Kilolo Kijakazi should be substituted, therefore, for Andrew Saul as the defendant in this suit. No further action need be taken to continue the suit by reason of the last sentence of section 205(g) of the Social Security Act § 405(g). 2 Transcript citations refer to the Sealed Administrative Record [Doc. #12].

83, 102-05) and upon reconsideration (Tr. at 84-101, 109-13). Thereafter, Plaintiff requested an administtative heating de novo before an Administrative Law Judge (“ALJ”). (I'r. at 116.) On March 26, 2019, Plaintiff, along with her attorney, attended the subsequent hearing, during which an impartial vocational expert testified. (I't. at 12.) The ALJ ultimately concluded that | Plaintiff was not disabled within the meaning of the Act (Ir. at 22-23), and, on February 11, 2020, the Appeals Council denied Plaintiff's request for review of the decision, thereby making the AL]’s conclusion the Commissionet’s final decision for purposes of judicial review (Tr. at 1-6). i. LEGAL STANDARD Federal law “authorizes judicial review of the Social Security Commissioner’s denial of social security benefits.” Hines v. Barnhart, 453 F.3d 559, 561 (4th Cir. 2006). However, “the

scope of [the] review of [such an administrative] decision . . . is extremely limited.” Frady v. Harris, 646 F.2d 143, 144 (4th Cir. 1981). “The courts are not to try the case de novo.” Oppenheim v. Finch, 495 F.2d 396, 397 (4th Cir. 1974). Instead, “a reviewing court must uphold the factual findings of the ALJ [underlying the denial of benefits] if they are supported by substantial evidence and were reached through application of the correct legal standard.” Hancock v. Asttue, 667 F.3d 470, 472 (4th Cir. 2012) (internal brackets omitted). “Substantial evidence means ‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Hunter v. Sullivan, 993 F.2d 31, 34 th Cir. 1993) (quoting Richardson v. Perales, 402 U.S. 389, 390 (1971)). “It consists of more than a mete scintilla of evidence but may be somewhat less than a preponderance.” Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001) (internal citations and quotation matks omitted). “If there is

evidence to justify a tefusal to ditect a verdict were the case before a jury, then there is substantial evidence.” Hunter, 993 F.2d at 34 (internal quotation marks omitted). “In reviewing for substantial evidence, the coutt should not undertake to re-weigh conflicting evidence, make credibility determinations, or substitute its judgment for that of the [AL]].” Mastro, 270 F.3d at 176 (internal brackets and quotation marks omitted). “Where conflicting evidence allows reasonable minds to differ as to whether a claimant is disabled, the responsibility for that decision falls on the ALJ.” Hancock, 667 F.3d at 472. “The issue before [the reviewing court], therefore, is not whether [the claimant] is disabled, but whether the AL)’s finding that [the claimant] is not disabled is supported by substantial evidence and was teached based upon a cottect application of the relevant law.” Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996). In undertaking this limited review, the Court notes that in administrative proceedings, claimant for disability benefits bears the burden of proving a disability.” Hall v. Harris, 658 F.2d 260, 264 (4th Cir. 1981). In this context, “disability” means the ““inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impaitment 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.” Id. (quoting 42 U.S.C. § 423(d)()(A))?

3 “The Social Security Act comprises two disability benefits programs. The Social Security Disability Insurance Program .. . provides benefits to disabled persons who have contributed to the program while employed. The Supplemental Security Income Program . . . provides benefits to indigent disabled persons. The statutory definitions and the regulations . . . for determining disability governing these two programs are, in all aspects relevant here, substantively identical.” Craig, 76 F.3d at 589 n.1 (internal citations omitted).

“The Commissioner uses a five-sten ptocess to evaluate disability claims.” Hancock, 667 F.3d at 472 (citing 20 C.F.R. §§ 404.1520(a)(4); 416.920(a)(4)). “Under this process, the Commissioner asks, in sequence, whether dhe Aaimante (1) worked during the alleged period of disability; (2) had a severe impairment; (3) had an impairment that met or equaled the requirements of a listed impaitment; (4) could return to her past relevant work; and (5) if not, could perform any other work in the national economy.” Id. A finding adverse to the claimant at any of several points in this five-step sequence fotecloses a disability designation and ends the inquity. For example, “[t]he first step determines siete: the claimant is engaged in ‘substantial gainful activity.’ If the claimant is working, benefits ate denied. The second step determines if the claimant is ‘severely’ disabled. If not, benefits are denied.” Bennett v. Sullivan, 917 F.2d 157, 159 (4th Cir. 1990).

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HAIRSTON v. KIJAKAZI, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hairston-v-kijakazi-ncmd-2021.