Hansen v. Saul

CourtDistrict Court, W.D. North Carolina
DecidedDecember 7, 2021
Docket5:20-cv-00193
StatusUnknown

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

Bluebook
Hansen v. Saul, (W.D.N.C. 2021).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA STATESVILLE DIVISION DOCKET NO. 5:20-cv-193-MOC

CHRISTIAN CORBETT HANSEN, ) ) Plaintiff, ) ) Vs. ) ORDER ) KILOLO KIJAKAZI, ) Acting Commissioner of Social Security, ) ) Defendant. )

THIS MATTER is before the Court on the parties’ opposing Motions for Summary Judgment. (Doc. Nos. 13, 16). Having carefully considered such motions and reviewed the pleadings, the Court enters the following findings, conclusions, and Order. FINDINGS AND CONCLUSIONS I. Administrative History Plaintiff filed an application for disability insurance benefits under Title II of the Act on September 19, 2014, alleging disability as of June 17, 2010 (Tr. 347–48). The agency denied Plaintiff’s application initially and upon reconsideration (Tr. 155–87). The ALJ held a hearing and denied Plaintiff’s disability claim in March 2018 (Tr. 95–149, 192–207). In March 2019, the Appeals Council granted Plaintiff’s request for review and remanded the ALJ’s March 2018 decision for the ALJ to apply the correct date last insured and address an unadjudicated period as well as further evaluate Plaintiff’s mental RFC to account for limitations describing his abilities in the unskilled work environment (Tr. 215–16). In December 2019, the same ALJ held another hearing where Plaintiff testified with the assistance of counsel (Tr. 35–94). An impartial vocational expert also

-1- testified (Id.). Plaintiff amended his alleged onset date to January 22, 2013 (Tr. 12, 496). On March 3, 2020, the ALJ issued a written decision finding that Plaintiff was not disabled under the Act (Tr. 12–28). On December 11, 2020, Plaintiff filed a complaint challenging a denial of Plaintiff’s claim for benefits by a Social Security Administrative Law Judge (“ALJ”) and a motion to proceed in forma pauperis (Doc. No. 1, 2). On December 21, 2020 the Court granted the motion to proceed in forma

pauperis (Doc. No. 3). In his complaint, Plaintiff asserts that he filed his claim for disability benefits on September 19, 2014 alleging disability beginning June 17, 2010, later amended to January 22, 2013. (Doc. No. 1 at 1). Plaintiff argues that he has now exhausted his administrative remedies. (Id.). He also argues that the final decision in his Social Security case “is not supported by substantial evidence and resulted from material errors of law committed by the ALJ.” (Id. at 2). Plaintiff seeks review of this decision under 42 U.S.C. § 405(g) and § 1383(c). (Id.). II. Factual Background It appears that the ALJ’s findings of fact are supported by substantial evidence. Therefore, the Court adopts and incorporates such findings herein as if fully set forth. Such findings are

referenced in the substantive discussion which follows. III. Standard of Review The only issues on review are whether the Commissioner applied the correct legal standards and whether the Commissioner’s decision is supported by substantial evidence. Richardson v. Perales, 402 U.S. 389, 390 (1971); Hays v. Sullivan, 907 F.2d 1453, 1456 (4th Cir. 1990). Review by a federal court is not de novo, Smith v. Schwieker, 795 F.2d 343, 345 (4th Cir. 1986); rather,

-2- inquiry is limited to whether there was “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Perales, 402 U.S. at 401 (internal citations omitted). Even if the Court were to find that a preponderance of the evidence weighed against the Commissioner's decision, the Commissioner's decision would have to be affirmed if it was supported by substantial evidence. Hays, 907 F.2d at 1456. The Fourth Circuit has explained substantial evidence review as follows:

the district court reviews the record to ensure that the ALJ's factual findings are supported by substantial evidence and that its legal findings are free of error. If the reviewing court decides that the ALJ's decision is not supported by substantial evidence, it may affirm, modify, or reverse the ALJ's ruling with or without remanding the cause for a rehearing. A necessary predicate to engaging in substantial evidence review is a record of the basis for the ALJ's ruling. The record should include a discussion of which evidence the ALJ found credible and why, and specific application of the pertinent legal requirements to the record evidence. If the reviewing court has no way of evaluating the basis for the ALJ's decision, then the proper course, except in rare circumstances, is to remand to the agency for additional investigation or explanation.

Radford v. Colvin, 734 F.3d 288, 295 (4th Cir. 2013) (internal citations and quotations omitted). IV. Substantial Evidence a. Introduction The Court has read the transcript of Plaintiff’s administrative hearing, closely read the decision of the ALJ, and reviewed the relevant exhibits contained in the extensive administrative record. The issue is not whether a court might have reached a different conclusion had it been presented with the same testimony and evidentiary materials, but whether the decision of the administrative law judge is supported by substantial evidence. For the following reasons, the Court finds that the ALJ’s decision was supported by substantial evidence.

-3- b. Sequential Evaluation The Act defines “disability” as an inability “to engage in 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)(2). To qualify for DIB under Title II of the Act, 42 U.S.C. §§ 416(i) and 423, an individual must meet the insured status requirements of these sections, be under

retirement age, file an application for disability insurance benefits and a period of disability, and be under a “disability” as defined in the Act. A five-step process, known as “sequential” review, is used by the Commissioner in determining whether a Social Security claimant is disabled. The Commissioner evaluates a disability claim pursuant to the following five-step analysis: a. An individual who is working and engaging in substantial gainful activity will not be found to be “disabled” regardless of medical findings; b. An individual who does not have a “severe impairment” will not be found to be disabled; c. If an individual is not working and is suffering from a severe impairment that meets the durational requirement and that “meets or equals a listed impairment in Appendix 1” of

Subpart P of Regulations No. 4, a finding of “disabled” will be made without consideration of vocational factors; d. If, upon determining residual functional capacity, the Commissioner finds that an individual is capable of performing work he or she has done in the past, a finding of “not disabled” must be made;

-4- e. If an individual's residual functional capacity precludes the performance of past work, other factors including age, education, and past work experience must be considered to determine if other work can be performed. 20 C.F.R.

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Hansen v. Saul, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hansen-v-saul-ncwd-2021.