Hilton v. Commissioner of Social Security Administration

CourtDistrict Court, D. South Carolina
DecidedApril 23, 2025
Docket6:24-cv-05698
StatusUnknown

This text of Hilton v. Commissioner of Social Security Administration (Hilton v. Commissioner of 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
Hilton v. Commissioner of Social Security Administration, (D.S.C. 2025).

Opinion

IN THE DISTRICT COURT OF THE UNITED STATES FOR THE DISTRICT OF SOUTH CAROLINA GREENVILLE DIVISION

Jason H.,1 ) ) C/A No. 6:24-cv-5698-DCC-KFM Plaintiff, ) ) REPORT OF MAGISTRATE JUDGE vs. ) ) Leland Dudek,2 ) Acting Commissioner of Social Security, ) ) Defendant. ) ) This case is before the court for a report and recommendation pursuant to Local Civil Rule 73.02(B)(2)(a) (D.S.C.), concerning the disposition of Social Security cases in this District, and 28 U.S.C. § 636(b)(1)(B).3 The plaintiff brought this action pursuant to Section 205(g) of the Social Security Act, as amended (42 U.S.C. 405(g)), to obtain judicial review of a final decision of the Commissioner of Social Security denying his claim for disability insurance benefits under Title II of the Social Security Act. ADMINISTRATIVE PROCEEDINGS Applicable to the instant matter, the plaintiff filed an application for disability insurance benefits (“DIB”) on October 18, 2021, alleging that he became unable to work on July 17, 2019 (Tr. 209–15). The application was denied initially (Tr. 91–99) and on 1 The Committee on Court Administration and Case Management of the Judicial Conference of the United States has recommended that due to significant privacy concerns in social security cases federal courts should refer to claimants only by their first names and last initials. 2 On February 16, 2025, Leland Dudek became the Acting Commissioner of Social Security. Pursuant to Federal Rule of Civil Procedure 25(d), he is automatically substituted for defendant Martin J. O’Malley, who was the Commissioner of Social Security when this action was filed. 3 A report and recommendation is being filed in this case in which one or both parties declined to consent to disposition by the magistrate judge. reconsideration (Tr. 100–08) by the Social Security Administration. On March 15, 2023, the plaintiff requested a hearing (Tr. 124–25). On December 5, 2023, an administrative hearing was held at which the plaintiff, represented by counsel, and Amy Vuyovich, an impartial vocational expert, appeared and testified via telephone before the administrative law judge (“ALJ”) assigned to the case (Tr. 34–65). On March 12, 2024, the ALJ considered the case de novo and found that the plaintiff was not under a disability as defined in the Social Security Act, as amended (Tr. 17–33). The ALJ’s decision also noted that res judicata applied to bar the plaintiff’s DIB claim for the period from July 17, 2019, to August 16, 2021, based on a prior ALJ decision that the plaintiff did not appeal (Tr. 17). The ALJ’s finding became the final decision of the Commissioner of Social Security when the Appeals Council denied the plaintiff’s request for review on August 12, 2024 (Tr. 1–4). The plaintiff then filed this action for judicial review (doc. 1). In making the determination that the plaintiff is not entitled to benefits, the Commissioner has adopted the following findings of the ALJ: (1) The claimant meets the insured status requirements of the Social Security Act through December 31, 2025. (2) The claimant has not engaged in substantial gainful activity since August 17, 2021, the amended onset date (20 C.F.R. § 404.1571 et seq.). (3) The claimant has the following severe impairments: lumbar degenerative disc disease and arthropathy; osteoarthritis of knee (20 C.F.R. § 404.1520(c)). (4) 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 C.F.R. Part 404, Subpart P, Appendix 1 (20 C.F.R. §§ 404.1520(d), 404.1525, and 404.1526). (5) After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform sedentary work as defined in 20 C.F.R. § 404.1567(a) except with the following limitations: The claimant can lift and carry 20 pounds occasionally and 10 pounds frequently. He is able to stand and walk a total 2 hours in an 8-hour workday and is able to sit for 6 hours. He can occasionally climb ramps and stairs and occasionally balance, 2 stoop, kneel, crouch, and crawl. He is not able to climb ladders, ropes, or scaffolds. He can occasionally reach overhead with the dominant right upper extremity and frequently reach all other directions with the right upper extremity. He is able to tolerate frequent exposure to extreme heat, cold, and humidity. He cannot tolerate exposure to hazards such as uneven terrain, unprotected heights, and heavy moving machinery that requires agility or alertness to avoid or evade. He cannot operate motor vehicles. He is able to sustain concentration, persistence, and pace to stay on task to complete simple, routine, repetitive tasks. (6) The claimant is unable to perform any past relevant work (20 C.F.R. § 404.1565). (7) The claimant was born on March 21, 1976, and was 43 years old, which is defined as a younger individual age 18-44, on the alleged disability onset date. The claimant subsequently changed age category to a younger individual age 45-49 (20 C.F.R. § 404.1563). (8) The claimant has at least a high school education (20 C.F.R. § 404.1564). (9) Transferability of job skills is not material to the determination of disability because using the Medical-Vocational Rules as a framework supports a finding that the claimant is “not disabled,” whether or not the claimant has transferable job skills (See SSR 82-41 and 20 C.F.R. Part 404, Subpart P, Appendix 2). (10) 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 C.F.R. §§ 404.1569 and 404.1569a). (11) The claimant has not been under a disability, as defined in the Social Security Act, from August 17, 2021, through the date of this decision (20 C.F.R. § 404.1520(g)). The only issues before the court are whether proper legal standards were applied and whether the final decision of the Commissioner is supported by substantial evidence. APPLICABLE LAW Under 42 U.S.C. § 423

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Hilton v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hilton-v-commissioner-of-social-security-administration-scd-2025.