KING v. KIJAKAZI

CourtDistrict Court, M.D. North Carolina
DecidedMarch 21, 2022
Docket1:20-cv-01008
StatusUnknown

This text of KING v. KIJAKAZI (KING v. KIJAKAZI) 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
KING v. KIJAKAZI, (M.D.N.C. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA HUBERT KING, ) ) Plaintiff, ) ) v. ) 1:20CV 1008 ) KILOLO KIJAKAZI} ) Acting Commissioner of Social Security, ) ) Defendant. ) MEMORANDUM OPINION AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE, Plaintiff Hubert King (“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 patties have filed ctoss-motions for judgment, and the administrative record has been certified to the Court for review. I. PROCEDURAL HISTORY Plaintiff protectively filed his application for SSI on January 11, 2016. (Tr. at 17, 332- 40.)? His claim was denied initially (Ir. at 74-86, 130-41), and that determination was upheld on reconsideration (I'r. at 87-104, 142-51). Thereafter, Plaintiff requested an administrative heating de novo before an Administrative Law Judge (“ALJ”). (Tr. at 152.) Plaintiff did not

' Kilolo Kijakazi became 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 as the defendant in this suit. 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¢). 2 Transcript citations refer to the Administrative Record [Doc. #9].

appeat at his original hearing (T'r. at 105-09), but upon appeal, the Appeals Council directed the ALJ to offer him an opportunity for a new hearing (Tr. 14, 111-12). Plaintiff, along with his attorney and an impartial vocational expert, attended the subsequent heating on March 2, 2020. (Ir. at 14.) Following the heating, the ALJ concluded that Plaintiff was not disabled within the meaning of the Act (Tr. at 25), and on September 14, 2020, the Appeals Council denied Plaintiffs request for a review of that decision, thereby making the ALJ’s conclusion the Commissionet’s final decision for purposes of judicial review (Tr. at 2-7). 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 [the] review of [such an administrative] decision . . . is extremely limited.” Frady v. Harris, 646 F.2d 143, 144 (4th Cir. 1981). “The courts 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 ALJ [underlying the denial of benefits] if they are supported by substantial evidence and were reached through application of the cortect legal standard.” Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012) (internal brackets 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) (quoting Richardson v. Perales, 402 U.S. 389, 390 (1971)). “It consists of more than a mete scintilla of evidence but may be somewhat less than a preponderance.” Mastro v. Apfel, 270 F.3d 171, 176 (4th Cit. 2001) (internal citations and quotation marks omitted). “If thete 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 marks omitted). “In reviewing for substantial evidence, the court should not undettake to re-weigh conflicting evidence, make credibility determinations, or substitute its jadgment for that of the [ALJ].” Mastro, 270 F.3d at 176 (internal brackets and quotation marks omitted). “Where conflicting evidence allows reasonable 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. “The issue before [the reviewing court], therefore, is not whether [the claimant] is disabled, but whether the AL)’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 review, the Court notes that in administrative proceedings, “[a] claimant for disability benefits beats the burden of proving a disability.” Hall v. Hartis, 658 F.2d 260, 264 (4th Cir. 1981). In this context, “disability” means the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impaitment which can be expected to result in death or which has lasted or can be expected to last for a continuous petiod of not less than 12 months.” Id. (quoting 42 U.S.C. § 423(d)(1)(A))?

> “The Social Security Act comprises two disability benefit programs. The Social Security Disability Insurance Program . . . provides benefits to disabled persons who have contributed to the program while employed. The Supplemental Security Income Program . . . provides benefits to indigent disabled persons. The statutory definitions and the regulations . . . for determining disability governing these two programs are, in all aspects relevant here, substantively identical.” Craig, 76 F.3d at 589 n.1 (internal citations omitted).

“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 period of disability; (2) had a severe impairment; (3) had an impaitment that met or equaled the requirements of a listed impairments; (4) could return to [his] 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.

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Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
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826 F.3d 176 (Fourth Circuit, 2016)
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Billie J. Woods v. Nancy Berryhill
888 F.3d 686 (Fourth Circuit, 2018)
Margaret Shinaberry v. Andrew Saul
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Hancock v. Astrue
667 F.3d 470 (Fourth Circuit, 2012)

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Bluebook (online)
KING v. KIJAKAZI, Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-v-kijakazi-ncmd-2022.