Kirby v. Saul

CourtDistrict Court, W.D. North Carolina
DecidedMarch 25, 2022
Docket3:21-cv-00235
StatusUnknown

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

Bluebook
Kirby v. Saul, (W.D.N.C. 2022).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION 3:21-cv-235-MOC

JODY LYNN KIRBY, ) ) Plaintiff, ) ) vs. ) ORDER ) KILOLO KIJAKAZI, ) Commissioner of Social Security, ) Defendant. ) ___________________________________ )

THIS MATTER is before the Court on the parties’ opposing Motions for Summary Judgment. (Doc. Nos. 15, 17). Having carefully considered such motions and reviewed the pleadings, the Court enters the following findings, conclusions, and Order. FINDINGS AND CONCLUSIONS I. Administrative History Plaintiff seeks judicial review of the Social Security Administration’s decision denying his July 17, 2015, applications for a period of disability and Disability Insurance Benefits (DIB) and supplemental security income (SSI) benefits under Titles II & XVI of the Act, 42 U.S.C. § 423(a), alleging disability beginning May 10, 2015. (Tr. 167). Plaintiff was last insured for Title II benefits on March 31, 2018. (Tr. 169). An administrative hearing was held on December 12, 2017. (Tr. 44–70). An ALJ issued a denial decision on July 11, 2018 (Tr. 167–78), which decision was vacated and remanded for another hearing by the Commissioner’s Appeals Council (AC) on October 15, 2019. (Tr. 185–89). The original vacated decision found that Plaintiff did not have a severe mental impairment. (Tr. 170). On remand, the AC pointed out that State agency medical consultants found moderate mental impairment based upon the diagnosis of traumatic brain injury. (Tr. 187). Furthermore, the AC directed the case be sent for hearing and decision by another ALJ to moot Plaintiff’s constitutional appointments clause challenge to the original ALJ “because, on July 16, 2018, the Acting Commissioner of Social Security ratified all Administrative Law Judge appointments and approved them as her own under the Constitution.” (Tr. 188).

A second ALJ hearing was held on May 21, 2020, by the new ALJ. (Tr. 44–70). The new ALJ issued a decision on August 12, 2020. (Tr. 22–35). The Agency’s AC denied review of this decision on March 19, 2021, making the ALJ’s decision the final decision of the Commissioner. (Tr. 1–7). In denying review, the AC refused to exhibit six pages of neuroscience evidence dated after the current ALJ decision because under the revised regulations this evidence did “not present a reasonable probability of changing the outcome of the decision.” (Tr. 2). Plaintiff now seeks judicial review of the Commissioner’s final decision pursuant to 42 U.S.C. § 405(g). II. Factual Background It appearing that the ALJ’s findings of fact are supported by substantial evidence, the

Court adopts and incorporates such findings herein as if fully set forth. Such findings are referenced in the substantive discussion which follows. III. Standard of Review The only issues on review are whether the Commissioner applied the correct legal standards and whether the Commissioner’s decision is supported by substantial evidence. Richardson v. Perales, 402 U.S. 389, 390 (1971); Hays v. Sullivan, 907 F.2d 1453, 1456 (4th Cir. 1990). Review by a federal court is not de novo, Smith v. Schwieker, 795 F.2d 343, 345 (4th Cir. 1986); rather, inquiry is limited to whether there was “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Perales, 402 U.S. at 401 (internal citations omitted). Even if the Court were to find that a preponderance of the evidence weighed against the Commissioner's decision, the Commissioner's decision would have to be affirmed if it was supported by substantial evidence. Hays, 907 F.2d at 1456. The Fourth Circuit has explained substantial evidence review as follows: the district court reviews the record to ensure that the ALJ's factual findings are supported by substantial evidence and that its legal findings are free of error. If the reviewing court decides that the ALJ's decision is not supported by substantial evidence, it may affirm, modify, or reverse the ALJ's ruling with or without remanding the cause for a rehearing. A necessary predicate to engaging in substantial evidence review is a record of the basis for the ALJ's ruling. The record should include a discussion of which evidence the ALJ found credible and why, and specific application of the pertinent legal requirements to the record evidence. If the reviewing court has no way of evaluating the basis for the ALJ's decision, then the proper course, except in rare circumstances, is to remand to the agency for additional investigation or explanation.

Radford v. Colvin, 734 F.3d 288, 295 (4th Cir. 2013) (internal citations and quotations omitted). IV. Substantial Evidence a. Introduction The Court has read the transcript of Plaintiff’s administrative hearing, closely read the decision of the ALJ, and reviewed the relevant exhibits contained in the extensive administrative record. The issue is not whether a court might have reached a different conclusion had it been presented with the same testimony and evidentiary materials, but whether the decision of the administrative law judge is supported by substantial evidence. For the following reasons, the Court finds that the ALJ’s decision was supported by substantial evidence. b. Sequential Evaluation The Act defines “disability” as an 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)(2). To qualify for DIB under Title II of the Act, 42 U.S.C. §§ 416(i) and 423, an individual must meet the insured status requirements of these sections, be under retirement age, file an application for disability insurance benefits and a period of disability, and be under a “disability” as defined in the Act. To qualify for Supplemental Security Income (SSI) disability benefits under Title XVI of the Act, insured status is not an eligibility

factor. However, income and resources are a factor. A five-step process, known as “sequential” review, is used by the Commissioner in determining whether a Social Security claimant is disabled. The Commissioner evaluates a disability claim pursuant to the following five-step analysis: a. An individual who is working and engaging in substantial gainful activity will not be found to be “disabled” regardless of medical findings; b. An individual who does not have a “severe impairment” will not be found to be disabled; c. If an individual is not working and is suffering from a severe impairment that meets

the durational requirement and that “meets or equals a listed impairment in Appendix 1” of Subpart P of Regulations No. 4, a finding of “disabled” will be made without consideration of vocational factors; d.

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Kirby v. Saul, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kirby-v-saul-ncwd-2022.