Jenkins v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedSeptember 2, 2021
Docket2:20-cv-00604
StatusUnknown

This text of Jenkins v. Social Security Administration, Commissioner (Jenkins v. Social Security Administration, Commissioner) is published on Counsel Stack Legal Research, covering District Court, N.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Jenkins v. Social Security Administration, Commissioner, (N.D. Ala. 2021).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

CARL JENKINS, ) ) Plaintiff, ) ) v. ) Case No. 2:20-cv-604-GMB ) KILOLO KIJAKAZI,1 Acting ) Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM OPINION

On December 20, 2018, Plaintiff Carl Jenkins filed an application for a period of disability and disability insurance benefits (“DIB”). His alleged disability onset date is May 1, 2016. Jenkins’ application for benefits was denied at the initial administrative level. He then requested a hearing before an Administrative Law Judge (“ALJ”). The ALJ held a hearing on December 12, 2019 and denied Jenkins’ claims on January 23, 2020. Jenkins requested a review of the ALJ’s decision by the Appeals Council, which declined review on March 9, 2020. As a result, the ALJ’s decision became the final decision of the Commissioner of the Social Security Administration (the “Commissioner”) as of March 9, 2020.

1 Kilolo Kijakazi became the Acting Commissioner of Social Security on July 9, 2021. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Kilolo Kijakazi should be substituted for Andrew Saul. No further action need be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g). Jenkins’ case is now before the court for review pursuant to 42 U.S.C. §§ 405(g). Under 28 U.S.C. § 636(c)(1) and Rule 73 of the Federal Rules of Civil

Procedure, the parties have consented to the full jurisdiction of a United States Magistrate Judge. Doc. 23. Based on a review of the parties’ submissions, the relevant law, and the record as a whole, the court concludes that the decision of the

Commissioner is due to be reversed and remanded. I. STANDARD OF REVIEW2 The court reviews a Social Security appeal to determine whether the Commissioner’s decision “is supported by substantial evidence and based upon

proper legal standards.” Lewis v. Callahan, 125 F.3d 1436, 1439 (11th Cir. 1997). The court will reverse the Commissioner’s decision if it is convinced that the decision was not supported by substantial evidence or that the proper legal standards

were not applied. Carnes v. Sullivan, 936 F.2d 1215, 1218 (11th Cir. 1991). The court “may not decide the facts anew, reweigh the evidence, or substitute its judgment for that of the Commissioner,” but rather “must defer to the Commissioner’s decision if it is supported by substantial evidence.” Miles v. Chater,

84 F.3d 1397, 1400 (11th Cir. 1997) (citation and internal quotation marks omitted).

2 In general, the legal standards are the same whether a claimant seeks DIB or Supplemental Security Income (“SSI”). However, separate, parallel statutes and regulations exist for DIB and SSI claims. Therefore, citations in this opinion should be considered to reference the appropriate parallel provision as context dictates. The same applies to citations for statutes or regulations found in excerpted court decisions. “Even if the evidence preponderates against the Secretary’s factual findings, [the court] must affirm if the decision reached is supported by substantial evidence.”

Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990). Moreover, reversal is not warranted even if the court would have reached a result contrary to that of the factfinder. See Edwards v. Sullivan, 937 F.2d 580, 584 n.3 (11th Cir. 1991).

The substantial evidence standard is met “if a reasonable person would accept the evidence in the record as adequate to support the challenged conclusion.” Holladay v. Bowen, 848 F.2d 1206, 1208 (11th Cir. 1988) (quoting Boyd v. Heckler, 704 F.2d 1207, 1209 (11th Cir. 1983)). The requisite evidentiary showing has been

described as “more than a scintilla, but less than a preponderance.” Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983). The court must scrutinize the entire record to determine the reasonableness of the decision reached and cannot “act as

[an] automaton[] in reviewing the [Commissioner’s] decision.” Hale v. Bowen, 831 F.2d 1007, 1010 (11th Cir. 1987). Thus, the court must consider evidence both favorable and unfavorable to the Commissioner’s decision. Swindle v. Sullivan, 914 F.2d 222, 225 (11th Cir. 1990).

The court will reverse the Commissioner’s decision on plenary review if the decision applies incorrect law or fails to provide the court with sufficient reasoning to determine that the Commissioner properly applied the law. Grant v. Astrue, 255

F. App’x 374, 375–76 (11th Cir. 2007) (citing Keeton v. Dep’t of Health & Human Servs., 21 F.3d 1064, 1066 (11th Cir. 1994)). There is no presumption that the Commissioner’s conclusions of law are valid. Id.

II. STATUTORY AND REGULATORY FRAMEWORK To qualify for disability benefits, a claimant must show the “inability 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 12 months.” 42 U.S.C. §§ 423(d)(1)(A) & 416(i). A physical or mental impairment is “an impairment that results from anatomical, physiological, or psychological

abnormalities which are demonstrated by medically acceptable clinical and laboratory diagnostic techniques.” 42 U.S.C. § 423(d)(3). Jenkins bears the burden of proving that he is disabled and is responsible for producing evidence sufficient to

support his claim. See Ellison v. Barnhart, 355 F.3d 1272, 1276 (11th Cir. 2003). A determination of disability under the Social Security Act requires a five- step analysis. 20 C.F.R. § 404.1520(a). The Commissioner must determine in sequence:

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Related

Deloris Grant v. Michael J. Astrue
255 F. App'x 374 (Eleventh Circuit, 2007)
Miles v. Chater
84 F.3d 1397 (Eleventh Circuit, 1996)
Lewis v. Callahan
125 F.3d 1436 (Eleventh Circuit, 1997)
Andrew T. Wilson v. Jo Anne B. Barnhart
284 F.3d 1219 (Eleventh Circuit, 2002)
Ellison v. Barnhart
355 F.3d 1272 (Eleventh Circuit, 2003)
Werner v. Commissioner of Social Security
421 F. App'x 935 (Eleventh Circuit, 2011)
Horton v. Barnhart
469 F. Supp. 2d 1041 (N.D. Alabama, 2006)
Alice Frame v. Commissioner, Social Security Administration
596 F. App'x 908 (Eleventh Circuit, 2015)
Edwards v. Sullivan
937 F.2d 580 (Eleventh Circuit, 1991)

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