Hinnant v. Kijakazi

CourtDistrict Court, E.D. North Carolina
DecidedSeptember 23, 2021
Docket5:20-cv-00058
StatusUnknown

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

Bluebook
Hinnant v. Kijakazi, (E.D.N.C. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA WESTERN DIVISION No. 5:20-CV-58-BO JACQUELINE HINNANT, ) Plaintiff, v. ORDER KILOLO KIJAKAZI, ; Commissioner of Social Security,! ) Defendant.

This cause comes before the Court on cross-motions for judgment on the pleadings. [DE 18, 22]. A hearing was held on these matters before the undersigned on September 16, 2021, at Edenton, North Carolina. For the reasons discussed below, the plaintiff's motion for judgment on the pleadings is granted and defendant’s motion is denied. BACKGROUND Plaintiff brought this action under 42 U.S.C. § 405(g) for review of the final decision of the Commissioner denying her application for period of disabled widow’s benefits as well as supplemental security income benefits pursuant to Titles II and XVI of the Social Security Act. Plaintiff alleged a disability onset date of February 1, 2012. After initial denials, plaintiff proceeded to a hearing before an Administrative Law Judge (ALJ), after which the ALJ issued an unfavorable ruling. The ALJ’s decision became the final decision of the Commissioner when the Appeals Council denied plaintiff's request for review. Plaintiff then sought review of the Commissioner’s decision in this Court.

' Kijakazi has been substituted as the proper defendant pursuant to Fed. R. Civ. P. 25(d).

DISCUSSION Under the Social Security Act, 42 U.S.C. § 405(g), this Court’s review of the Commissioner’s decision is limited to determining whether the decision, as a whole, is supported by substantial evidence and whether the Commissioner employed the correct legal standard. Richardson v. Perales, 402 U.S. 389, 401 (1971). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Johnson v. Barnhart, 434 F.3d 650, 653 (4th Cir. 2005) (per curiam) (internal quotation and citation omitted). An individual is considered disabled if he is unable “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 twelve months.” 42 U.S.C. § 1382c(a)(3)(A). The Act further provides that an individual “shall be determined to be under a disability only if his physical or mental impairment or impairments are of such severity that he is not only unable to do his previous work but cannot, considering his age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy.” 42 U.S.C. § 1382c(a)(3)(B). Regulations issued by the Commissioner establish a five-step sequential evaluation process to be followed in a disability case. 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4). The claimant bears the burden of proof at steps one through four, but the burden shifts to the Commissioner at step five. See Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987). If a decision regarding disability can be made at any step of the process the inquiry ceases. See 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4). At step one, if the Social Security Administration determines that the claimant is currently engaged in substantial gainful activity, the claim is denied. If not, then step two asks whether the

claimant has a severe impairment or combination of impairments. If the claimant has a severe impairment, it is compared at step three to those in the Listing of Impairments (“Listing”) in 20 C.F.R. Part 404, Subpart P, App. 1. If the claimant’s impairment meets or medically equals a Listing, disability is conclusively presumed. If not, at step four, the claimant’s residual functional capacity (RFC) is assessed to determine if the claimant can perform his past relevant work. If the claimant cannot perform past relevant work, then the burden shifts to the Commissioner at step five to show that the claimant, based on his age, education, work experience, and RFC, can perform other substantial gainful work. If the claimant cannot perform other work, then he is found to be disabled. See 20 C.F.R. § 416.920(a)(4). After determining that plaintiff has not engaged in substantial gainful activity at step one, the ALJ found that plaintiff had severe impairments — hypertension, Hepatitis C, rheumatoid arthritis, inflammatory polyarthropathy, obesity, depressive disorder, anxiety disorder, and post- traumatic stress disorder — that did not meet or medically equal the severity of one of the listed impairments. The ALJ found that plaintiff could perform medium work with both exertional and nonexertional limitations as follows: frequently push, pull, and operate hand controls with both upper extremities; occasionally climb ramps and stairs, but precluded from climbing ropes, ladders, and scaffolds; frequently balance, stoop, kneel, and crouch; occasionally crawl; frequently reach, reach overhead, handle objects, finger, and feel bilaterally; occasional exposure to unprotected heights, hazardous machinery, or hazardous moving mechanical parts; limited to simple, routine, repetitive tasks, but not a production rate pace and only frequent interaction with the public; and would be off task no more than ten percent of the workday, in addition to normal

breaks. The ALJ found that plaintiff had no past relevant work and determined at step five that jobs existed in significant numbers in the national economy which plaintiff could perform.” Plaintiff argues that the ALJ failed to sufficiently explain how he determined several aspects of plaintiff's RFC, preventing this Court from conducting a meaningful review of his decision. Radford v. Colvin, 734 F.3d 288, 296 (4th Cir. 2013). The Court agrees that, at a minimum, the ALJ failed to sufficiently explain what is intended by restricting plaintiff from work at a production rate pace or the basis for finding that plaintiff would be off-task ten percent of the day and that remand is necessary. An RFC assessment must be based on all of the relevant medical and other evidence. 20 C.F.R. § 404.1545(a). An RFC should reflect the most that a claimant can do, despite the claimant’s limitations. Jd. An ALJ’s decision “must include a narrative discussion describing how the evidence supports each conclusion, citing specific medical facts (e.g., laboratory findings) and nonmedical evidence (e.g., daily activities, observations).” Woods v. Berryhill, 888 F.3d 686, 694 (4th Cir. 2018) (quoting Mascio v.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Jimmy Radford v. Carolyn Colvin
734 F.3d 288 (Fourth Circuit, 2013)
Bonnilyn Mascio v. Carolyn Colvin
780 F.3d 632 (Fourth Circuit, 2015)
George Monroe v. Carolyn Colvin
826 F.3d 176 (Fourth Circuit, 2016)
Billie J. Woods v. Nancy Berryhill
888 F.3d 686 (Fourth Circuit, 2018)
Nikki Thomas v. Nancy Berryhill
916 F.3d 307 (Fourth Circuit, 2019)

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Bluebook (online)
Hinnant v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hinnant-v-kijakazi-nced-2021.