Henley v. O'Malley

CourtDistrict Court, S.D. Georgia
DecidedMarch 21, 2025
Docket1:24-cv-00089
StatusUnknown

This text of Henley v. O'Malley (Henley v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, S.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Henley v. O'Malley, (S.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE SOUTHERN DISTRICT OF GEORGIA

AUGUSTA DIVISION

TRACY J. HENLEY, ) ) Plaintiff, ) ) v. ) CV 124-089 ) LELAND DUDEK, Acting Commissioner ) of Social Security Administration,1 ) ) Defendant. ) _________________________________________________________

MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION _________________________________________________________ Plaintiff appeals the decision of the Acting Commissioner of Social Security (“the Commissioner”) denying her application for Supplemental Security Income (“SSI”) under the Social Security Act. Upon consideration of the briefs submitted by both parties, the record evidence, and the relevant statutory and case law, the Court REPORTS and RECOMMENDS pursuant to sentence four of 42 U.S.C. § 405(g), that the Commissioner’s final decision be AFFIRMED, and a final judgment be ENTERED in favor of the Commissioner. I. BACKGROUND Plaintiff protectively applied for SSI in September 2020,2 and she alleged a disability onset date of August 28, 2018. Tr. (“R.”), p. 251. Plaintiff was 48 in September 2020, and was 51 when

1 Pursuant to Fed. R. Civ. P. 25(d), the Court DIRECTS the CLERK to substitute Leland Dudek, Acting Commission of Social Security Administration, as the proper Defendant.

2 Plaintiff references September 23 as the application date while the ALJ and Commissioner reference September 8. The discrepancy is immaterial to the Court’s analysis. See discussion infra Section III.A. the Administrative Law Judge (“ALJ”) issued the decision under consideration. R. 21-23, 251. Plaintiff alleges disabilities of anemia, depression, back disorder, fractured foot, carpal tunnel syndrome, peripheral artery disease, hypertension, and mild obesity. R. 12-13, 291. Plaintiff

reported completing her GED, R. 292, 791, and prior to her alleged disability date accrued a history of past work as a babysitter, certified nursing assistant, housekeeper, and lead teacher. R. 280, 292. The Social Security Administration (“SSA”) denied Plaintiff’s application initially and on reconsideration. R. 136-70. Plaintiff requested a hearing before an ALJ, R. 189, and ALJ Christopher Daniels held a hearing on March 15, 2024, R. 36. Represented by counsel, Plaintiff appeared by phone and testified, as did a vocational expert (“VE”), Robert Brabham. R. 36-56. On April 11, 2024, the ALJ issued a decision finding Plaintiff not disabled. R. 10-23.

Applying the sequential process required by 20 C.F.R. § 416.920, the ALJ found: 1. The claimant has not engaged in substantial gainful activity (SGA) since September 8, 2020, the application date (20 CFR 416.971 et seq.).

2. The claimant has the following severe impairments: Hemolytic anemia (20 CFR 416.920(c)).

3. The claimant does not have an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1 (20 CFR 416.920(d), 416.925 and 416.926).

4. After careful consideration of the entire record, the undersigned finds the claimant has the residual functional capacity (“RFC”) to perform light work3 as defined in 20 CFR 416.967(b) except that the claimant can

3 “Light work” is defined as:

lifting no more than 20 pounds at a time with frequent lifting or carrying of objects weighing up to 10 pounds. Even though the weight lifted may be very little, a job is in this category when it requires a good deal of walking or standing, or when it involves sitting most of the time with some pushing and pulling of arm or leg controls. To be considered capable of performing a full or wide range of light work, you must have the ability to do substantially all of these activities. If someone can do light work, we determine that he or occasionally lift/carry 20 pounds, frequently lift/carry 10 pounds, push/pull the same as lift/carry, stand or walk 6 out of 8 hours, and sit 6 out of 8 hours. The claimant cannot climb ladders, ropes, or scaffolds, crawl, or have exposure to heights. The claimant can occasionally climb ramps and stairs, balance, stoop, kneel, and crouch. The claimant can frequently handle and finger with the right upper extremity. The claimant can have no more than occasional exposure to extreme cold, vibration, fumes, odors, dusts, gases, poor ventilation, and dangerous moving machinery.

The claimant has no past relevant work (20 CFR 416.965).

5. Considering the claimant’s age, education, work experience, and residual functional capacity, there are jobs that exist in significant numbers in the national economy that the claimant can perform (20 CFR 416.969, and 416.969a).

The claimant has not been under a disability, as defined in the Social Security Act, since September 8, 2020, the date the application was filed (20 CFR 416.920(g)).

R. 12-22.

When the Appeals Council denied Plaintiff’s request for review of the ALJ’s decision, R. 1-3, the Commissioner’s decision became “final” for the purpose of judicial review, 42 U.S.C. § 405(g). Plaintiff then filed this civil action requesting an immediate award of benefits, and in the alternative, remand, arguing the RFC is not supported by substantial evidence, the hypothetical questions posed to the VE failed to include all Plaintiff’s limitations and impairments, and the ALJ’s decision failed to apply res judicata principles based on a prior ALJ denial. (See doc. no. 9, “Pl.’s Br.”) The Commissioner maintains the decision to deny Plaintiff benefits is supported by substantial evidence, the VE’s testimony provides substantial evidence Plaintiff could perform

she can also do sedentary work, unless there are additional limiting factors such as loss of fine dexterity or inability to sit for long periods of time.

20 C.F.R. § 416.976(b). other work, and the ALJ did not have to apply administrative res judicata. (See doc. no. 12, “Comm’r’s Br.”) II. STANDARD OF REVIEW

Judicial review of social security cases is narrow and limited to the following questions: (1) whether the Commissioner’s findings are supported by substantial evidence, and (2) whether the Commissioner applied the correct legal standards. Lewis v. Callahan, 125 F.3d 1436, 1439 (11th Cir. 1997). When considering whether the Commissioner’s decision is supported by substantial evidence, the reviewing court may not decide the facts anew, reweigh the evidence, or substitute its judgment for the Commissioner’s. Moore v.

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Bluebook (online)
Henley v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/henley-v-omalley-gasd-2025.