Killion v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedSeptember 30, 2021
Docket5:20-cv-00279
StatusUnknown

This text of Killion v. Social Security Administration, Commissioner (Killion 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
Killion v. Social Security Administration, Commissioner, (N.D. Ala. 2021).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA NORTHEASTERN DIVISION JENNIFER KILLION, ) ) Plaintiff, ) ) v. ) Case No.: 5:20-cv-0279-LCB ) ANDREW SAUL, Commissioner of ) Social Security Administration, ) ) Defendant.

MEMORANDUM OPINION

On March 2, 2020, the Plaintiff, Jennifer Killion, filed a complaint seeking judicial review of an adverse decision of the Commissioner of the Social Security Administration (“the Commissioner”) pursuant to 42 U.S.C. § 405(g). The Commissioner filed an answer on June 29, 2020. Killion filed a brief in support of her position on September 11, 2020, and the Commissioner filed a response on October 13, 2020. Killion did not file a reply brief. Accordingly, the issue is now fully briefed and is ripe for review. For the reasons that follow, the Commissioner’s final decision is affirmed. I. Background Killion protectively filed an application for a period of disability and disability insurance benefits on June 30, 2018, alleging disability beginning July 1, 2016. After the claim was denied on August 29, 2018, Killion requested a hearing before an Administrative Law Judge (“ALJ”). That hearing was held on January 8, 2019. Killion was represented by counsel and testified at the hearing, as did a

vocational expert (“VE”). The ALJ subsequently issued an unfavorable decision. Killion then requested review of the ALJ’s decision by the Appeals Council, but that request was denied on February 5, 2020, and the Commissioner’s decision

became final. This lawsuit followed. II. The ALJ’s decision After the hearing, the ALJ issued a written opinion explaining his decision. (Tr. pp. 18-25)1. In issuing his decision, the ALJ followed the five-step evaluation

process set out by the Social Security Administration. 20 CFR 416.920(a). The steps are followed in order and, if it is determined that the claimant is or is not disabled at a particular step of the evaluation process, the ALJ will not proceed to

the next step. The first step requires the ALJ to determine whether the claimant is engaging in substantial gainful activity, which is defined as work involving significant physical or mental activities usually done for pay or profit. If a claimant is

engaged in substantial gainful activity, she is not disabled, and the inquiry stops. Otherwise, the ALJ will proceed to step two. In the present case, the ALJ found that Killion did not engage in substantial gainful activity between July 1, 2016, the

1 References to “Tr” denote the page numbers in the transcript prepared by the Commissioner appearing in the Court’s CM/ECF system at (Doc. 7-2). alleged onset date, and December 31, 2018, the date she was last insured. (Tr. p. 20). Accordingly, the ALJ moved on to the second step of the evaluation.

At step two, an ALJ is to determine whether the claimant has a medically determinable impairment that is “severe” or a combination of impairments that is “severe.” 20 CFR 416.920(c). An impairment is severe if it “significantly limits

[a claimant’s] physical or mental ability to do basic work activities….” Id. If a claimant does not have a severe impairment, she is not disabled, and the inquiry ends. If she does have a severe impairment, the ALJ will proceed to the third step. In the present case, the ALJ found that Killion had the following severe

impairments: dysautonomia, tachycardia, and irritable bowel syndrome. (Tr. p. 21). At the third step, an ALJ determines whether the claimant’s impairments or

combination thereof are of a severity to meet or medically equal the criteria of an impairment listed in 20 CFR Part 404, Subpart P, Appendix I. If the claimant’s impairment or impairments meet or equal a listed impairment, then the claimant is disabled, and the evaluation ends. Otherwise, the ALJ proceeds to the next step.

In this case, the ALJ found that Killion’s impairments did not meet or equal any of the listed criteria and, therefore, proceeded to step four. (Tr. p. 21). Step four of the evaluation requires an ALJ to determine the claimant’s

residual functional capacity (“RFC”), and whether she has the RFC to perform the requirements of any past relevant work. 20 CFR 416.920(f). The term “past relevant work” means work performed within the last 15 years prior to the alleged

date of onset. If a claimant has the RFC to perform past relevant work, she is not disabled, and the evaluation stops. Otherwise, the evaluation proceeds to the final step. In Killion’s case, the ALJ found that she had the RFC to perform her past

work as a benefits manager and office manager. (Tr. p. 21). Therefore, he determined that Killion was not disabled as defined by the Social Security Administration and did not proceed to the final step of the evaluation process. III. Standard of Review

The Court must determine whether the Commissioner’s decision is supported by substantial evidence and whether the correct legal standards were applied. Winschel v. Comm'r of Social Sec., 631 F.3d 1176, 1178 (11th Cir. 2011).

“Substantial evidence is more than a scintilla and is such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Id. (internal citation and quotation marks omitted). “This limited review precludes deciding the facts anew, making credibility determinations, or re-weighing the evidence.”

Moore v. Barnhart, 405 F.3d 1208, 1211 (11th Cir. 2005). Thus, while the Court must scrutinize the record as a whole, the Court must affirm if the decision is supported by substantial evidence, even if the evidence preponderates against the Commissioner’s findings. Henry v. Comm'r of Soc. Sec., 802 F.3d 1264 (11th Cir. 2015); Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983).

IV. Killion’s arguments Killion raises three arguments in her brief. First, she argues that the ALJ’s decision is not supported by substantial evidence because, she says, his findings

regarding her RFC were incomplete and unsupported by the evidence. Second, she alleges that the ALJ considered her impairments separately and not in combination as the law requires. Finally, Killion contends that the ALJ improperly rejected her subjective testimony regarding the severity of her symptoms. The Court will

address each argument in turn. A. The ALJ’s decision, including his RFC determination, is supported by substantial evidence.

The ALJ determined that Killion’s RFC was as follows: the claimant had the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) except the claimant can occasionally climb ramps and stairs, but never ladders or scaffolds. The claimant can frequently balance, but occasionally stoop, kneel, crouch, and crawl. The claimant can occasionally tolerate exposure to extreme heat and cold.

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Related

Castel v. Commissioner of Social Security
355 F. App'x 260 (Eleventh Circuit, 2009)
Christi L. Moore v. Jo Anne B. Barnhart
405 F.3d 1208 (Eleventh Circuit, 2005)
Winschel v. Commissioner of Social Security
631 F.3d 1176 (Eleventh Circuit, 2011)
Scott Delia v. Commissioner of Social Security
433 F. App'x 885 (Eleventh Circuit, 2011)
Thomas Scott Henry v. Commissioner of Social Security
802 F.3d 1264 (Eleventh Circuit, 2015)
Kinnard v. Commissioner of Social Security
426 F. App'x 835 (Eleventh Circuit, 2011)

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Killion v. Social Security Administration, Commissioner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/killion-v-social-security-administration-commissioner-alnd-2021.