KIDD v. O'MALLEY

CourtDistrict Court, M.D. North Carolina
DecidedMarch 28, 2024
Docket1:22-cv-01041
StatusUnknown

This text of KIDD v. O'MALLEY (KIDD v. O'MALLEY) is published on Counsel Stack Legal Research, covering District Court, M.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
KIDD v. O'MALLEY, (M.D.N.C. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA BRANDON kK,, ) ) Plaintiff, ) ) V. ) 1:22CV1041 ) MARTIN J. O7MALLEY;,! ) Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER OF UNITED STATES MAGISTRATE JUDGE Plaintiff Brandon K. (“Plaintiff’) brought this action pursuant to Section 1631(c)(3) of the Social Security Act (the “Act”), as amended (42 U.S.C. § 1383(c)(3)), to obtain judicial review of a final decision of the Commissioner of Social Security denying his claim for Supplemental Security Income (“SSI”) under Title XVI of the Act. The Parties have filed cross-briefs, and the administrative record has been certified to the Court for review. L. PROCEDURAL HISTORY Plaintiff initially recetved SSI benefits based on disability as a child. (Tr. at 151.)? As tequited by law, the agency redetermined Plaintiffs eligibility for benefits under the rules for determining disability in adults when Plaintiff turned 18. On October 25, 2019, it was

December 20, 2023, Martin J. O'Malley was sworn in as Commissioner of Soctal Security, replacing Acting Commissioner Kilolo Kijakazi. Pursuant to Rule 25(d) of the Federal Rules of Ctvil Procedure, Martin J. O’Malley should be substituted for Kilolo Kijakazi as Defendant in this suit. No further action need be taken to continue this suit by reason of the last sentence of section 405(g) of the Social Security Act, 42 U.S.C. § 405(g). 2 Transcript citations refer to the Sealed Administrative Record [Doc. #4].

determined that Plaintiff was no longer disabled, and that decision was upheld upon reconsideration. (Tr. at 151, 179-81.) Thereafter, Plaintiff requested an administrative hearing de novo before an Administrative Law Judge (“ALJ”). (Tr. at 217-20.) On May 19, 2021, Plaintiff, represented by an attorney, appeated and testified at the subsequent telephonic hearing, at which both Plaintiff and an impartial vocational expert testified. (Tr. at 151.) Following the hearing, the ALJ issued a decision concluding that Plaintiff was not disabled within the meaning of the Act. (It. at 160.) However, in an order dated January 18, 2022, the Appeals Council vacated the AL]’s decision and remanded the case for a new heating. (Tr. at 15, 167-74.) Accordingly, on May 31, 2022, the ALJ held a video heating at which Plaintiff

was again represented by an attorney and during which both Plaintiff and an impartial vocational expert testified. (Ir. at 15.) In a decision dated June 9, 2022, the AL] again concluded that Plaintiffs disability ended on October 25, 2019, and that Plaintiff had not become disabled again since that date. (Tr. at 26.) On October 4, 2022, the Appeals Council denied review of that decision, thereby making the ALJ’s conclusion the Commissionet’s final decision for purposes of judicial review. (I'r. at 1-6.) Il. LEGAL STANDARD Federal law “authorizes judicial review of the Social Security Commissionet’s denial of social security benefits.” Hines v. Barnhart, 453 F.3d 559, 561 (4th Cir. 2006). However, the

scope of review of such a decision is “extremely limited.” Frady v. Harris, 646 F.2d 143, 144 (4th Cir. 1981). “The coutts ate not to try the case de novo.” Oppenheim v. Finch, 495 F.2d 396, 397 (4th Cir. 1974). Instead, “a reviewing court must uphold the factual findings of the AL] if they are supported by substantial evidence and were reached through application of the

correct legal standard.” Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012) (internal brackets and quotation omitted). “Substantial evidence means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Hunter _v. Sullivan, 993 F.2d 31, 34 (4th Cir. 1993) (internal quotation omitted). “It consists of more than a mete scintilla of evidence but may be somewhat less than a preponderance.” Mastto v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001) (internal brackets and quotation omitted). “If there is evidence to justify a refusal to direct a verdict were the case before a jury, then there is substantial evidence.” Hunter, 993 F.2d at 34 (internal quotation omitted). “In reviewing for substantial evidence, the court should not undertake to te-weigh conflicting evidence, make credibility determinations, or substitute its jadgment for that of the [AL]].” Mastro, 270 F.3d at 176 (internal brackets and quotation omitted). “Where conflicting evidence allows teasonable minds to differ as to whether a claimant is disabled, the responsibility for that decision falls on the ALJ.” Hancock, 667 F.3d at 472 (internal brackets and quotation omitted). “The issue before [the reviewing court], therefore, is not whether [the claimant] is disabled, but whether the ALJ’s finding that [the claimant] is not disabled is supported by substantial evidence and was reached based upon a cortect application of the relevant law.” Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996). In undertaking this limited teview, the Court notes that “[a] claimant for disability benefits bears the burden of proving a disability.” Hall v. Harris, 658 F.2d 260, 264 (4th Cir. 1981). “The Commissioner uses a five-step process to evaluate disability claims.” Hancock, 667 F.3d at 472 (citing 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4)). “Under this process, the ,

Commissioner asks, in sequence, whether the claimant: (1) worked during the alleged petiod of disability; (2) had a severe impairment; (3) had an impairment that met or equaled the requirements of a listed impairment; (4) could return to her past relevant work; and (5) if not, could perform any other work in the national economy.” Id. A finding adverse to the claimant at any of several points in this five-step sequence forecloses a disability designation and ends the inquity. For example, “[t]he first step determines whether the claimant is engaged in ‘substantial gainful activity.’ If the claimant is working, benefits are denied. The second step determines if the claimant is ‘severely’ disabled. If not, benefits are denied.” Bennett v. Sullivan, 917 F.2d 157, 159 (4th Cir. 1990). On the other hand, if a claimant catties his or her burden at the first two steps, and if the claimant’s impairment meets or equals a “listed impairment” at step three, the claimant is disabled. Mastto, 270 F.3d at 177. Alternatively, if a claimant clears steps one and two, but falters at step three, ie., “[iJf a claimant’s impairment is not sufficiently severe to equal or exceed a listed impairment,” then “the ALJ must assess the claimant’s residual functional capacity (RFC?).” Id.

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KIDD v. O'MALLEY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kidd-v-omalley-ncmd-2024.