Jackson v. COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION

CourtDistrict Court, W.D. Tennessee
DecidedAugust 22, 2025
Docket2:24-cv-02058
StatusUnknown

This text of Jackson v. COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION (Jackson v. COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION) is published on Counsel Stack Legal Research, covering District Court, W.D. Tennessee primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jackson v. COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION, (W.D. Tenn. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TENNESSEE WESTERN DIVISION

SHEILA A. JACKSON, ) ) Plaintiff, ) ) No. 2:24-cv-02058-TLP-cgc v. ) ) COMMISSIONER OF SOCIAL ) SECURITY ADMINISTRATION, ) ) Defendant. )

ORDER AFFIRMING DECISION OF THE COMMISSIONER

Plaintiff Sheila Jackson seeks judicial review of the Commissioner of Social Security Administration’s (“SSA”) decision denying her disability insurance benefits under Title II of the Social Security Act. For the reasons below, the Court AFFIRMS the Commissioner’s decision. BACKGROUND The Court will first explain the five-step process an administrative law judge (“ALJ”) uses to decide whether an applicant is disabled. After that, the Court will describe the eight-step process an ALJ uses to decide whether a disability claimant continues to be disabled. The Court also sets out the ALJ’s findings about whether Plaintiff continues to be disabled and her medical conditions. Then, the Court will present the procedural history of this case. I. Five-Step Sequential Process Under the Social Security Act, the first question is whether Plaintiff is disabled. Congress defines “[d]isability” as “the inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment . . . which has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A). And to decide whether a person is disabled, the ALJ uses a five-step evaluation. 20 C.F.R. § 404.1520(a)(4)(i–v). The applicant bears the burden of proving the first four steps. See Her v. Comm’r of Soc. Sec., 203 F.3d 388, 391 (6th Cir. 1999) (citing Bowen v. Yuckert, 482

U.S. 137, 146 (1987)). But, at the fifth step, “[t]he burden of proof shifts to the Commissioner . . . [to prove] that there is work available in the economy” that Plaintiff can perform. Id. at 391. The ALJ first looks at whether the applicant is currently engaged in substantial gainful activity (“SGA”). See 20 C.F.R. § 404.1520(a). SGA is “work activity that involves doing significant physical or mental activities.” 20 C.F.R. § 416.972(a)(4)(i). If the applicant is engaged in SGA, then the analysis ends there. See 20 C.F.R. § 404.1520(a)(4)(i). The ALJ then analyzes in the second step whether the applicant has a medically determinable impairment, or a combination of impairments, that meets the definition of “severe.” See 20 C.F.R. § 404.1520(a)(4)(ii). An impairment is “severe” if it significantly limits the person’s ability to perform basic work activities. See 20 C.F.R. § 416.920(c). But the

impairment is not severe if the medical information establishes only a “slight abnormality that minimally affects work ability regardless of age, education, and experience.” Higgs v. Bowen, 880 F.2d 860, 862 (6th Cir. 1988). In the third step, the ALJ must determine whether the applicant’s impairments either meet or medically equal the criteria of an Appendix 1 listing. 20 C.F.R. § 404.1520(a)(4)(iii). If so, the applicant is disabled. Id. If not, the ALJ looks further to determine the applicant’s “residual functional capacity” (“RFC”) to perform past work. 20 C.F.R. § 404.1545. RFC refers to an individual’s ability to do physical and mental work on a sustained basis despite the limitations from the impairments. 20 C.F.R. § 404.1520(e). Fourth, if she has the RFC to perform the requirements of her past relevant work, the applicant is not disabled, and the analysis ends here. See 20 C.F.R. § 404.1520(a)(4)(iv). But if the applicant does not have the RFC to return to her past work, then the analysis goes on to the fifth and final step. Id. Finally, the ALJ will evaluate the applicant’s ability to do any other

work given her RFC, age, education, and work experience. See 20 C.F.R. § 404.1520(a)(4)(v). If the applicant cannot perform other work, then she qualifies as disabled. Id. II. Eight-Step Continuing Disability Test But if an applicant qualifies for and receives benefits, that is not the end of the inquiry for forever. Rather the SSA periodically reviews disability benefit recipients’ cases to determine whether they remain disabled. 20 C.F.R. § 404.1594(a). In deciding whether a claimant is still disabled, the SSA decides on a “neutral basis” with no “initial inference as to the presence or absence of disability being drawn from the fact that [the claimant has] previously been determined to be disabled.” 20 C.F.R. § 404.1594(b)(6). But unlike in an initial proceeding, “the ultimate burden of proof lies with the Commissioner in termination proceedings.” Kennedy

v. Astrue, 247 F. App’x 761, 765 (6th Cir. 2007). When deciding whether a claimant continues to be disabled, the SSA, and its ALJs, follow an eight-step process. See 20 C.F.R. § 404.1594(f). In this eight-step continuing disability evaluation, the ALJ first looks at whether the claimant is currently engaged in substantial gainful activity (“SGA”). 20 C.F.R. § 404.1594(f)(1). If the applicant is engaged in SGA, then the analysis ends there. (Id.) But if not, the ALJ moves to step two where the ALJ analyzes whether the claimant’s impairments either meet or medically equal the criteria of an Appendix 1 listing. 20 C.F.R. § 404.1594(f)(2). If not, the ALJ goes to step three to assess whether there has been medical improvement. 20 C.F.R. § 404.1594(f)(3). The definition of medical improvement appears in the C.F.R. Medical improvement is any decrease in the medical severity of your impairment(s) which was present at the time of the most recent favorable medical decision that you were disabled or continued to be disabled. A determination that there has been a decrease in medical severity must be based on improvement in the symptoms, signs, and/or laboratory findings associated with your impairment(s).

20 C.F.R. § 404.1594(b)(1). If there is medical improvement, the ALJ proceeds to step four. 20 C.F.R.

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Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Yer Her v. Commissioner of Social Security
203 F.3d 388 (Sixth Circuit, 1999)
Ruby E. Heston v. Commissioner of Social Security
245 F.3d 528 (Sixth Circuit, 2001)
Blakley v. Commissioner of Social Security
581 F.3d 399 (Sixth Circuit, 2009)
Bass v. McMahon
499 F.3d 506 (Sixth Circuit, 2007)
Kennedy v. Comm Social Security
247 F. App'x 761 (Sixth Circuit, 2007)
Ronald Miller v. Comm'r of Social Security
811 F.3d 825 (Sixth Circuit, 2016)
Biestek v. Commissioner of Social Security
880 F.3d 778 (Sixth Circuit, 2017)
Higgs v. Bowen
880 F.2d 860 (Sixth Circuit, 1988)

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Bluebook (online)
Jackson v. COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jackson-v-commissioner-of-social-security-administration-tnwd-2025.