Jones v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedSeptember 25, 2023
Docket2:22-cv-00741
StatusUnknown

This text of Jones v. Social Security Administration, Commissioner (Jones 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
Jones v. Social Security Administration, Commissioner, (N.D. Ala. 2023).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION

RODNEY JONES, ) )

) Plaintiff, )

) v. )

) Case No.: 2:22-cv-741-AMM SOCIAL SECURITY ) ADMINISTRATION, ) Commissioner, )

) Defendant. )

MEMORANDUM OF DECISION Plaintiff Rodney Jones brings this action pursuant to the Social Security Act (the “Act”), seeking review of the decision of the Commissioner of Social Security (“Commissioner”) denying his claim for a period of disability and disability insurance benefits (“benefits”). See 42 U.S.C. § 405(g). Based on the court’s review of the record, the court AFFIRMS the decision of the Commissioner. I. INTRODUCTION On November 1, 2019, Mr. Jones protectively filed an application for a period of disability and disability insurance benefits under Title II of the Act, alleging disability as of May 1, 2018. R. 11, 125–41. Mr. Jones alleged disability due to Human Immunodeficiency Virus (“HIV”), delusional disorder, type 2 diabetes mellitus, hypertension, peripheral neuropathy, post-traumatic stress disorder (“PTSD”), anxiety disorder, Barrett’s esophagus, abnormal brain scan, and psychosis. R. 126–27. He has at least a high school education and has past relevant

work experience as an accountant and a tech support specialist. R. 30–31. The Social Security Administration (“SSA”) initially denied Mr. Jones’s application on July 2, 2020. R. 11, 125–41, 174–80. Mr. Jones’s request for

reconsideration was denied on October 23, 2020. R. 11, 142–68, 181–85. Mr. Jones filed a request for a hearing before an Administrative Law Judge (“ALJ”) on December 10, 2020. R. 11, 186. That request was granted. R. 187–89. Mr. Jones received a video hearing before ALJ Mary E. Helmer on August 11, 2021. R. 11,

71–104, 218–50. At the hearing, Mr. Jones appeared and testified with the assistance of his attorney, Stephen Rygiel. R. 11, 71–104. Mr. Jones’s friend, Janet Griffin, appeared and testified at the hearing. R. 11, 71–104. An impartial vocational expert,

Lakeisha Rogers, also appeared and testified at the hearing. R. 11, 71–104. On August 24, 2021, ALJ Helmer issued a decision, finding that Mr. Jones was not under a disability from May 1, 2018, through the date of the decision. R. 11–33. Mr. Jones was fifty-five years old at the alleged disability onset date, and was fifty-nine

years old at the time of the ALJ decision. R. 31. Mr. Jones appealed to the Appeals Council, R. 251–53, which denied his request for review on April 12, 2022, R. 1–4. After the Appeals Council denied Mr.

Jones’s request for review, the ALJ’s decision became the final decision of the Commissioner and subject to district court review. R. 1–4. On June 14, 2022, Mr. Jones sought this court’s review of the ALJ’s decision. See Doc. 1.

II. THE ALJ’S DECISION The Act establishes a five-step test for the ALJ to determine disability. 20 C.F.R. § 404.1520. First, the ALJ must determine whether the claimant is engaging

in substantial gainful activity. 20 C.F.R. § 404.1520(a)(4)(i). “Substantial work activity is work activity that involves doing significant physical or mental activities.” 20 C.F.R. § 404.1572(a). “Gainful work activity” is work that is done for pay or profit. 20 C.F.R. § 404.1572(b). If the ALJ finds that the claimant engages in

substantial gainful activity, then the claimant cannot claim disability. 20 C.F.R. § 404.1520(b). Second, the ALJ must determine whether the claimant has a medically determinable impairment or a combination of medical impairments that significantly

limits the claimant’s ability to perform basic work activities. 20 C.F.R. § 404.1520(a)(4)(ii), (c). Absent such impairment, the claimant may not claim disability. Id. Third, the ALJ must determine whether the claimant’s impairment meets or medically equals the criteria of an impairment listed in 20 C.F.R. § 404,

Subpart P, Appendix 1. See 20 C.F.R. §§ 404.1520(d), 404.1525, 404.1526. If such criteria are met, the claimant is declared disabled. 20 C.F.R. § 404.1520(a)(4)(iii). If the claimant does not fulfill the requirements necessary to be declared

disabled under the third step, the ALJ still may find disability under the next two steps of the analysis. The ALJ must first determine the claimant’s residual functional capacity, which refers to the claimant’s ability to work despite his impairments. 20

C.F.R. §§ 404.1520(e), 404.1545. In the fourth step, the ALJ determines whether the claimant has the residual functional capacity to perform past relevant work. 20 C.F.R. § 404.1520(a)(4)(iv). If the ALJ determines that the claimant is capable of

performing past relevant work, then the claimant is deemed not disabled. Id. If the ALJ finds the claimant unable to perform past relevant work, then the analysis proceeds to the fifth and final step. Id. In this step, the ALJ must determine whether the claimant is able to perform any other work commensurate with his residual

functional capacity, age, education, and work experience. 20 C.F.R. § 404.1520(g)(1). Here, the burden of proof shifts from the claimant to the Commissioner to prove the existence, in significant numbers, of jobs in the national

economy that the claimant can do given his residual functional capacity, age, education, and work experience. 20 C.F.R. §§ 404.1520(g)(1), 404.1560(c). The ALJ determined that Mr. Jones would meet the insured status requirements of the Act through December 31, 2021. R. 11, 13. Next, the ALJ found

that Mr. Jones “ha[d] not engaged in substantial gainful activity since May 1, 2018, the alleged onset date.” R. 13. The ALJ explained that, although Mr. Jones “worked after the alleged disability onset date,” such “work activity did not rise to the level

of substantial gainful activity” and “[wa]s an unsuccessful work attempt.” R. 13. The ALJ further explained that Mr. Jones “receiv[ed] unemployment benefits . . . in the second quarter of 2020,” and “testified that he has applied for many jobs consistent

with his past work.” R. 13. The ALJ decided that Mr. Jones had the following severe impairments: diabetes mellitus, HIV, degenerative disc disease of the lumbar spine, hiatal hernia

with gastroesophageal reflux disease (“GERD”), anemia, Barrett’s esophagus, and obesity. R. 14. The ALJ found that Mr. Jones’s non-melanoma skin cancer, hypothyroidism, urticarial, GERD, obstructive sleep apnea, right adrenal gland removal, hypertension, and significantly decreased energy were not severe

impairments because they did not “cause more than a minimal impact on [Mr.

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