Hurst v. King

CourtDistrict Court, D. Minnesota
DecidedJanuary 14, 2025
Docket0:23-cv-03350
StatusUnknown

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

Bluebook
Hurst v. King, (mnd 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

April H.,1

Plaintiff, Case No. 23-cv-3350 (LMP/LIB)

v. REPORT AND RECOMMENDATION

Carolyn W. Colvin, Acting Commissioner of the Social Security Administration,

Defendant.

Plaintiff, April H. (hereinafter “Plaintiff”), seeks judicial review of the decision of the Commissioner of Social Security (“Defendant”) denying her application for disability benefits. The matter is before the undersigned United States Magistrate Judge for disposition pursuant to 28 U.S.C. § 636 and Local Rules 7.2(a)(1). This Court has jurisdiction over the claims under 42 U.S.C. § 405(g). Pursuant to the Federal Supplemental Rules of Civil Procedure which govern actions seeking judicial review of a decision of the Commissioner of Social Security, the present action “is presented for decision by the parties’ brief.” Fed. R. Civ. P. Supp. SS Rule 5. Plaintiff filed a brief along with supporting memorandum requesting that the present action be remanded to the Social Security Administration. [Docket Nos. 13, 14]. Defendant filed a brief asking this Court to affirm the underlying decision denying Plaintiff’s request for benefits and to dismiss this action. [Docket No. 15].

1 This District has adopted the policy of using only the first name and last initial of any nongovernmental parties in Social Security opinions such as the present Report and Recommendation. Thus, when the Court refers to Plaintiff by her name only her first name and last initial are provided. For the reasons discussed herein, the undersigned recommends that Plaintiff’s request to remand this matter, [Docket No. 14], be GRANTED, and Defendant’s request to affirm the underlying decision, [Docket No. 16], be DENIED. I. BACKGROUND On October 21, 2021, Plaintiff filed a Title II application for a period of disability and disability benefits, as well as a Title XVI application for supplemental social security income. (Tr. 15, 202–203, 204-213).2 In both of her applications, Plaintiff alleged that her disability began on

March 12, 2020. (Tr. 15, 231, 279). The Commissioner initially denied Plaintiff’s claims on January 18, 2022, and again, upon reconsideration, on April 21, 2022. (Tr. 15, 57, 76, 86–87). On April 28, 2022, Plaintiff filed a written request for a hearing before an Administrative Law Judge. (Tr. 10, 130–131). Administrative Law Judge Mikel Lupisella (hereinafter “ALJ”) conducted a telephonic hearing on September 8, 2022. (Tr. 15, 32–56). Plaintiff testified at the hearing, along with an independent vocational expert, Teresa McClain, (“IVE McClain”). (Tr. 15, 21). At the hearing, Plaintiff was represented by counsel. (Tr. 10, 27–86). On October 5, 2022, the ALJ issued a decision denying Plaintiff’s request for a period of disability and disability insurance benefits, as well as, Plaintiff’s request for supplemental social

security income. (Tr. 15–26). The ALJ concluded that Plaintiff was not disabled within the meaning of the Social Security Act. (Tr. 26). Plaintiff thereafter sought review of the decision by the Appeals Council. (Tr. 1–6, 197– 199). Subsequently, on September 8, 2023, the Appeals Council denied Plaintiff’s request for

2 Throughout this Report and Recommendation, the Court refers to the Administrative Record, [Docket No. 12], by the abbreviation “Tr.” The Administrative Record is consecutively paginated across 73 exhibits. (See Administrative Record [Docket No. 12]). Where the Court cites to the Administrative Record, it refers to the page numbers found in the bottom-right corner of those exhibits. review. (Tr. 1–6). As a result, the ALJ’s decision became the final decision of the Commissioner. See 20 C.F.R. §§ 404.981, 416.1481. On October 31, 2023, Plaintiff filed this action. (Compl. [Docket No. 1]). Thereafter, this matter was presented to the Court for review pursuant to the parties’ briefs, [Docket Nos. 14, 16], and the Court took the matter under advisement on the written submissions. II. STANDARDS OF REVIEW A. Administrative Law Judge’s Five-Step Analysis

If a claimant’s initial application for disability benefits is denied, she may request reconsideration of the decision. 20 C.F.R. §§ 404.907–404.909. A claimant who is dissatisfied with the reconsidered decision may then obtain administrative review by an administrative law judge (“ALJ”). 42 U.S.C. § 405(b)(1); 20 C.F.R. § 404.929. To determine the existence and extent of a claimant’s disability, the ALJ must follow a five-step sequential analysis. This analysis requires the ALJ to make a series of factual findings about the claimant’s impairments, residual functional capacity, age, education, and work experience. See 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4); Locher v. Sullivan, 968 F.2d 725, 727 (8th Cir. 1992). The Eighth Circuit has described this five-step process as follows: The Commissioner of Social Security [through the ALJ] must evaluate: (1) whether the claimant is presently engaged in a substantial gainful activity; (2) whether the claimant has a severe impairment that significantly limits the claimant’s physical or mental ability to perform basic work activities; (3) whether the claimant has an impairment that meets or equals a presumptively disabling impairment listed in the regulations; (4) whether the claimant has the residual functional capacity to perform his or her past relevant work; and (5) if the claimant cannot perform the past work, the burden shifts to the Commissioner to prove that there are other jobs in the national economy that the claimant can perform.

Dixon v. Barnhart, 353 F.3d 602, 605 (8th Cir. 2003). B. Appeals Council Review If the claimant is dissatisfied with the ALJ’s decision, she may request review by the Appeals Council, although the Appeals Council need not grant that request for review. See 20 C.F.R. §§ 404.967–404.982. The decision of the Appeals Council (or, if the request for review is denied by the Appeals Council, then the decision of the ALJ) is final and binding upon the claimant, unless the matter is appealed to federal court within sixty days after notice of the Appeals Council’s action. See 42 U.S.C. § 405(g); 20 C.F.R. § 404.981. In this case, the Appeals Council

declined to review the ALJ’s decision finding that Plaintiff was not disabled. (Tr. 1). C. Judicial Review Judicial review of the administrative decision generally proceeds by considering the decision of the ALJ at each of the five steps. Judicial review of the Commissioner’s decision to deny disability benefits, however, is constrained to a determination of whether the decision is supported by substantial evidence in the record as a whole. 42 U.S.C.

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