Harris v. Commissioner of Social Security

CourtDistrict Court, M.D. Florida
DecidedMarch 23, 2023
Docket8:22-cv-00323
StatusUnknown

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

Bluebook
Harris v. Commissioner of Social Security, (M.D. Fla. 2023).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

TEMIA HARRIS o/b/o K.L.F.,

Plaintiff,

v. Case No. 8:22-cv-323-MAP

COMMISSIONER OF SOCIAL SECURITY

Defendant. /

ORDER

Plaintiff seeks judicial review of the denial of her minor child’s (Claimant) claim for Supplemental Security Income (SSI).1 Plaintiff argues that the Administrative Law Judge (ALJ) committed reversible error by (1) failing to consider and find that Claimant met the Listing for intellectual disorders; and (2) finding that Claimant did not functionally equal the listings in severity because Claimant had a less than marked limitation in the domain of attending and completing tasks. As the ALJ’s decision was not based on substantial evidence and failed to employ proper legal standards, the Commissioner’s decision is reversed and remanded. I. Background

Claimant, who was born in 2006, claimed disability beginning July 1, 2011 (Tr. 131-32). He was four years old on the alleged onset date. Claimant was a school-aged

1 The parties have consented to my jurisdiction. See 28 U.S.C. § 636(c). child on May 9, 2019, the application date and on the date of the ALJ’s decision (Tr. 23). Specifically, at the time of the decision, Claimant was 14 years old and in the ninth grade (Tr. 47). Claimant had no work history (Tr. 144).

Given Claimant’s alleged disability, Plaintiff protectively filed an application for SSI on behalf of Claimant (Tr. 131-40). The Social Security Administration (SSA) denied Claimant’s claims both initially and upon reconsideration (Tr. 61-96). Plaintiff then requested an administrative hearing (Tr. 97-99). Per Plaintiff’s request, the ALJ held a hearing at which Plaintiff appeared and testified (Tr. 37-60). Following the

hearing, the ALJ issued an unfavorable decision finding Claimant not disabled and accordingly denied Claimant’s claims for benefits (Tr. 19-36). In rendering the administrative decision, the ALJ concluded that Claimant had not engaged in substantial gainful activity since May 9, 2019, the application date (Tr. 23). After conducting a hearing and reviewing the evidence of record, the ALJ

determined that Claimant had the following severe impairments: attention deficit hyperactivity disorder (ADHD), speech/language disorder, and asthma (Tr. 23). Notwithstanding the noted impairments, the ALJ determined that Claimant did not have an impairment or combination of impairments that met or medically equaled one of the listed impairments in 20 C.F.R. Part 404, Subpart P, Appendix 1 (Tr. 23). The

ALJ also determined that Claimant did not have an impairment or combination of impairments that functionally equaled the severity of the listings (Tr. 24). In making that determination, the ALJ found that Claimant experienced a marked limitation in acquiring and using information; a less than marked limitation in attending and completing tasks, moving about and manipulating objects, and health and physical well-being; and no limitation in interacting and relating with others and in the ability to care for himself (Tr 25). The ALJ then concluded that Claimant had not been

disabled since May 9, 2019 (Tr. 30). Given the ALJ’s finding, Plaintiff requested review from the Appeals Council, which the Appeals Council denied (Tr. 1-6, 125-28). Plaintiff then timely filed a complaint with this Court on behalf of Claimant (Doc. 1). The case is now ripe for review under 42 U.S.C. §§ 405(g), 1383(c)(3). II. Standard of Review

To be entitled to benefits, an individual under the age of 18 must demonstrate that he or she “has a medically determinable physical or mental impairment, which results in marked and severe functional limitations, and 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. § 1382c(a)(3)(C)(i). Like the approach taken

with adults, the Commissioner assesses child disability claims under a sequential analysis. 20 C.F.R. § 416.924(a). The first step requires the Commissioner to determine whether the child is performing substantial gainful activity. 20 C.F.R. § 416.924(a) & (b). If so, a finding of not disabled is warranted. 20 C.F.R. § 416.924(a) & (b). If not, the second step asks whether the child has a severe impairment. 20

C.F.R. § 416.924(a) & (c). If the child does not have a severe impairment, the child is considered not disabled. 20 C.F.R. § 416.924(a) & (c). If a severe impairment exists, the third and final step in the analysis involves a determination whether the child has an impairment that meets, medically equals, or functionally equals a set of criteria in the Listing of Impairments in 20 C.F.R. Part 404, Subpart P, Appendix 1. 20 C.F.R. § 416.924(a) & (d). For a child’s impairment(s) to functionally equal the listings, the child’s

impairment(s) must result in “marked” limitations in two domains of functioning or an “extreme” limitation in one domain of functioning. 20 C.F.R. § 416.926a(a). A child has a “marked” limitation in a domain when the impairment(s) interferes seriously with his or her ability to independently initiate, sustain, or complete activities. 20 C.F.R. § 416.926a(e)(2)(i). A “marked” limitation is “more than

moderate” but “less than extreme.” 20 C.F.R. § 416.926a(e)(2)(i). A child has an “extreme” limitation when the child’s impairment(s) interferes very seriously with the child’s ability to independently initiate, sustain, or complete activities and the limitation is “more than marked.” 20 C.F.R. § 416.926a(e)(3)(i). An extreme limitation is assigned only to the worst limitations but does not necessarily mean a

total lack or loss of ability to function. 20 C.F.R. § 416.926a(e)(3)(i). In assessing functional equivalence, the Commissioner considers the child’s functioning in terms of the following six domains: (1) acquiring and using information, (2) attending and completing tasks, (3) interacting and relating with others, (4) moving about and manipulating objects, (5) caring for oneself, and (6) health and physical well-being. 20

C.F.R. § 416.926a(b)(1)(i)-(vi), (g)-(l). These domains represent broad areas of functioning intended to capture all of what a child can or cannot do. Social Security Ruling (SSR) 09-1P, 2009 WL 396031, at *1 (Feb. 17, 2009).

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Harris v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/harris-v-commissioner-of-social-security-flmd-2023.