Howard v. Kijakazi

CourtDistrict Court, E.D. North Carolina
DecidedMarch 24, 2023
Docket4:21-cv-00166
StatusUnknown

This text of Howard v. Kijakazi (Howard 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
Howard v. Kijakazi, (E.D.N.C. 2023).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA EASTERN DIVISION No. 4:21-CV-166-BO

CLIFTON HOWARD, ) Plaintiff, ) ) V. ) ORDER ) KILOLO KIJAKAZI, ) Acting Commissioner of Social Security. ) Defendant. )

This cause comes before the Court on cross-motions for judgment on the pleadings. A hearing was held before the undersigned on February 15, 2023, at Elizabeth City, North Carolina and the motions are ripe for ruling. For the reasons that follow, plaintiff's motion is granted and the matter is remanded to the Commissioner for an award of benefits. BACKGROUND Plaintiff brought this action under 42 U.S.C. § 405(g) for review of the final decision of the Commissioner denying his application for disability and disability insurance benefits pursuant to Title I] of the Social Security Act. Plaintiff filed the instant application for disability benefits in January 2013. Plaintiff received his first unfavorable decision from an administrative law judge (ALJ) in April 2015. Plaintiff sought judicial review in this Court, and the decision was remanded for further proceedi1gs:. On remand, another hearing was held and the AL J issuecl an unfavorable decision. Plaintiff again sought judicial review and the decision of the ALJ was again remanded for further proceedings. The ALJ held another hearing and again issued an unfavorable decision on July 7, 2021. 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 decision in this Court. 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 or she 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 regard ing 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 or combination of impairments 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 or her age, education, work experience, and RFC, can perform other substantial gainful work. If the claimant cannot perform other work, then he or she is found to be disabled. See 20 C.F.R. § 416.920(a)(4). At step one, the ALJ determined that plaintiff last met the insured status requirements on December 31, 2014, and that he did not engage in substantial gainful activity from his alleged onset date through his date last insured. The ALJ found plaintiff's history of right crush fracture with residuals/chronic pain syndrome/carpal tunnel syndrome/neuropathy; adhesive capsulitis of the right upper extremity; and degenerative disc disease to be severe impairments at step two but that either alone or in combination plaintiff's impairments did not meet or medically equal a Listing at step three. The ALJ found plaintiff had the RFC to perform light work with limitations and that at step four plaintiff could perform his past relevant work through the date last insured. The ALJ further found at step five that other jobs existed in significant numbers which plaintiff could perform based upon his age, education, work experience, and RFC. Substantial evidence does not support the ALJ’s conclusion that plaintiff could perform a reduced range of light work on a regular and consistent basis. In September 2012, a different ALJ

rendered a final decision denying plaintiff's application for benefits which plaintiff did not appeal. Tr. 76-86. An ALJ must consider a prior ALJ’s decision and RFC finding as evidence and give it appropriate weight in light of all relevant facts and circumstances. AR 00-|(4), 2000 WL 43774, *4 (2000)'; see also Albright v. Comm’r of the SSA, 174 F.3d (4" Cir. 1999). The prior ALJ limited plaintiff to a reduced range of light work as well but found plaintiff could only lift and carry up to ten pounds with his right hand, occasionally push and pull with his right upper extremity, and occasionally finger, feel, and handle with the right hand. Tr. 80. In the instant decision on appeal, the ALJ placed no weight restrictions on plaintiff's right hand other than the light work restrictions” and limited plaintiff to frequent use of his right upper extremity for pushing, pulling, and reaching (except for overhead reaching), handling, fingering, and feeling. Tr. 780. The record does not contain substantial evidence of improvement in plaintiff's right upper extremity during the relevant time period, and specifically the period between the amended alleged onset date in November 2013 to plaintiff's December 2014 date last insured. In order to distinguish

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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)
Edwards v. Bowen
672 F. Supp. 230 (E.D. North Carolina, 1987)
Stacy Lewis v. Nancy Berryhill
858 F.3d 858 (Fourth Circuit, 2017)
Esin Arakas v. Commissioner, Social Security
983 F.3d 83 (Fourth Circuit, 2020)

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Bluebook (online)
Howard v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/howard-v-kijakazi-nced-2023.