Henry v. Commissioner of the Social Security Administration

CourtDistrict Court, D. South Carolina
DecidedOctober 29, 2021
Docket4:20-cv-02464
StatusUnknown

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

Bluebook
Henry v. Commissioner of the Social Security Administration, (D.S.C. 2021).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION AMBER HENRY, ) Civil Action No.: 4:20-cv-02464-TER ) Plaintiff, ) ) ORDER -vs- ) ) Kilolo Kijakazi,1 ) Acting Commissioner of Social Security, ) ) Defendant. ) ___________________________________ ) _________________________ This is an action brought pursuant to Section 205(g) of the Social Security Act, as amended, 42 U.S.C. Section 405(g), to obtain judicial review of a “final decision” of the Commissioner of Social Security, denying Plaintiff’s claim for supplemental security income(SSI). The only issues before the Court are whether the findings of fact are supported by substantial evidence and whether proper legal standards have been applied. This action is proceeding before the undersigned pursuant to 28 U.S.C. § 636(c) and Fed. R. Civ. Proc. R. 73. I. RELEVANT BACKGROUND A. Procedural History Plaintiff filed an SSI application on January 5, 2017, alleging disability beginning on February 1, 1996. (Tr. 14). Her claims were denied initially and upon reconsideration. Thereafter, Plaintiff filed a request for a hearing. A hearing was held on May 10, 2019, at which time Plaintiff and a vocational expert (VE) testified. (Tr. 14). The Administrative Law Judge (ALJ) issued an unfavorable decision on July 5, 2019, finding that Plaintiff was not disabled within the meaning of 1 Kilolo Kijakazi is the Acting Commissioner of Social Security. Pursuant to Fed. R. Civ. P. 25(d), she is automatically substituted for Defendant Andrew Saul who was the Commissioner of Social Security when this action was filed. the Act. (Tr. 14-23). Plaintiff filed a request for review of the ALJ’s decision. The Appeals Council denied the request for review. On June 29, 2020, Plaintiff filed this action. (ECF No. 1). B. Plaintiff’s Background and Medical History Plaintiff was born on May 2, 1991, and was twenty-five years old and the date the application

was filed. (Tr. 21). Plaintiff had no past relevant work. Plaintiff alleges disability originally due to schizophrenia, bipolar, depression, dyslexia, and blackouts. (Tr. 97). Relevant records will be addressed under the pertinent issue headings. C. The ALJ’s Decision In the decision of July 5, 2019, the ALJ made the following findings of fact and conclusions of law (Tr. 14-23): 1. The claimant has not engaged in substantial gainful activity since January 5, 2017, the application date (20 CFR 416.971 et seq.). 2. The claimant has the following severe impairments: borderline intellectual functioning ("BIF"); schizoaffective disorder; and post-traumatic stress disorder ("PTSD") (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, I find that the claimant has the residual functional capacity to perform a full range of work at all exertional levels but with the following non-exertional limitations: simple routine tasks with verbal instructions; jobs with a GED reasoning level of 1; occasional coworker contact; frequent supervisor contact; public contact no more than 10% of workday; no direct customer service work and no fastpaced work; can tolerate occasional changes in workplace and or work methods; can concentrate on, focus and attend to work tasks for at least two hours at a time, before needing a normal break of 15 minutes, or once per day, a 30 minute meal break. 2 5. The claimant has no past relevant work (20 CFR 416.965). 6. The claimant was born on May 2, 1991 and was 25 years old, which is defined as a younger individual age 18-49, on the date the application was filed (20 CFR 416.963). 7. The claimant has at least a high school education and is able to communicate in English (20 CFR 416.964). 8. Transferability of job skills is not an issue because the claimant does not have past relevant work (20 CFR 416.968). 9. 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). 10. The claimant has not been under a disability, as defined in the Social Security Act, since January 5, 2017, the date the application was filed (20 CFR 416.920(g)). II. DISCUSSION Plaintiff argues the ALJ improperly evaluated Dr. Thompson’s opinions. Plaintiff argues the ALJ erred in assessing Plaintiff’s “credibility.” (ECF No. 14 at 2). Defendant argues the ALJ applied the correct law and relied on substantial evidence in finding Plaintiff not disabled. A. LEGAL FRAMEWORK 1. The Commissioner’s Determination–of–Disability Process The Act provides that disability benefits shall be available to those persons insured for benefits, who are not of retirement age, who properly apply, and who are under a “disability.” 42 U.S.C. § 423(a). Section 423(d)(1)(A) defines disability as: the 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 at least 12 3 consecutive months. 42 U.S.C. § 423(d)(1)(A). To facilitate a uniform and efficient processing of disability claims, regulations promulgated under the Act have reduced the statutory definition of disability to a series of five sequential questions. See, e.g., Heckler v. Campbell, 461 U.S. 458, 460 (1983) (discussing considerations and

noting the “need for efficiency” in considering disability claims). An examiner must consider the following: (1) whether the claimant is engaged in substantial gainful activity (“SGA”); (2) whether he has a severe impairment; (3) whether that impairment meets or equals an impairment included in the Listings;2 (4) whether such impairment prevents claimant from performing PRW;3 and (5) whether the impairment prevents him from doing SGA. See 20 C.F.R. § 404.1520. These considerations are sometimes referred to as the “five steps” of the Commissioner’s disability analysis.

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Bluebook (online)
Henry v. Commissioner of the Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/henry-v-commissioner-of-the-social-security-administration-scd-2021.