Lawson v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedJune 29, 2022
Docket4:21-cv-00196
StatusUnknown

This text of Lawson v. Social Security Administration, Commissioner (Lawson 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
Lawson v. Social Security Administration, Commissioner, (N.D. Ala. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA MIDDLE DIVISION

TIMOTHY LAWSON, } } Plaintiff, } } v. } Case No.: 4:21-cv-00196-ACA } COMMISSIONER, } SOCIAL SECURITY } ADMINISTRATION, } } Defendant. }

MEMORANDUM OPINION

Plaintiff Timothy Lawson appeals the decision of the Commissioner of Social Security denying his claims for a period of disability, disability insurance benefits, and supplemental security income. Based on the court’s review of the administrative record and the parties’ briefs, the court WILL AFFIRM the Commissioner’s decision. I. PROCEDURAL HISTORY In May 2019, Mr. Lawson applied for a period of disability, disability insurance benefits, and supplemental security income, alleging that his disability began on July 4, 2018. (R. at 16, 249–64).1 The Commissioner initially denied Mr.

1 Mr. Lawson originally alleged that his disability began on June 29, 2018, but he amended his alleged onset date during the administrative hearing. (R. at 16, 38–39) Lawson’s claim and his request for reconsideration (id. at 186–96, 201–05), and Mr. Lawson requested a hearing before an Administrative Law Judge (“ALJ”) (id.

at 197). After holding a hearing (r. at 36–78), the ALJ issued an unfavorable decision (id. at 13–30). The Appeals Council denied Mr. Lawson’s request for review (id. at 1–7), making the Commissioner’s decision final and ripe for the

court’s judicial review. See 42 U.S.C. §§ 405(g), 1383(c). II. STANDARD OF REVIEW The court’s role in reviewing claims brought under the Social Security Act is a narrow one. The court “must determine whether the Commissioner’s decision is

supported by substantial evidence and based on proper legal standards.” Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011) (quotation marks omitted). “Under the substantial evidence standard, this court will affirm the ALJ’s

decision if there exists such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Henry v. Comm’r of Soc. Sec., 802 F.3d 1264, 1267 (11th Cir. 2015) (quotation marks omitted). The court may not “decide the facts anew, reweigh the evidence, or substitute [its] judgment for that of the [ALJ].”

Winschel, 631 F.3d at 1178 (quotation marks omitted). The court must affirm “[e]ven if the evidence preponderates against the Commissioner’s findings.” Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155, 1158–59 (11th Cir. 2004)

(quotation marks omitted). Despite the deferential standard for review of claims, the court must “scrutinize the record as a whole to determine if the decision reached is reasonable

and supported by substantial evidence.” Henry, 802 F.3d at 1267 (quotation marks omitted). Moreover, the court must reverse the Commissioner’s decision if the ALJ does not apply the correct legal standards. Cornelius v. Sullivan, 936 F.2d 1143,

1145–46 (11th Cir. 1991). III. ALJ’S DECISION To determine whether an individual is disabled, an ALJ follows a five-step sequential evaluation process. The ALJ considers:

(1) whether the claimant is currently engaged in substantial gainful activity; (2) whether the claimant has a severe impairment or combination of impairments; (3) whether the impairment meets or equals the severity of the specified impairments in the Listing of Impairments; (4) based on a residual functional capacity (“RFC”) assessment, whether the claimant can perform any of his or her past relevant work despite the impairment; and (5) whether there are significant numbers of jobs in the national economy that the claimant can perform given the claimant’s RFC, age, education, and work experience.

Winschel, 631 F.3d at 1178. Here, the ALJ determined that Mr. Lawson had not engaged in substantial gainful activity since his July 4, 2018, alleged onset date. (R. at 19). The ALJ found that Mr. Lawson’s degenerative disc disease, degenerative joint disease of the left knee, obesity, chronic obstructive pulmonary disease, traumatic brain injury, depression, anxiety, and post-traumatic stress disorder were severe impairments but that his sleep apnea, high blood pressure and cholesterol, type 2 diabetes, allergic rhinitis, and migraine headaches were non-severe impairments. (Id.). The ALJ then

concluded that Mr. Lawson does not suffer from an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments in 20 C.F.R. § 404, Subpart P, Appendix 1. (Id. at 19–21).

After considering the evidence of the record, the ALJ determined that Mr. Lawson had the residual functional capacity to perform sedentary work as defined in 20 C.F.R. §§ 404.1567(a) and 416.967(a) except that he faced some additional physical, postural, environmental, and mental limitations. (R. at 21).

Based on this residual functional capacity, the ALJ found that Mr. Lawson was unable to perform any past relevant work. (Id. at 24–25). But based on the testimony of a vocational expert, the ALJ concluded that jobs existed in significant numbers in

the national economy that Mr. Lawson could perform, including dowel inspector, ceramic tile examiner, and lens inserter. (Id. at 25–26). Accordingly, the ALJ determined that Mr. Lawson had not been under a disability, as defined in the Social Security Act, from his alleged July 4, 2018, onset date through the date of the

decision. (R. at 26). IV. DISCUSSION Mr. Lawson argues that the court should reverse and remand the

Commissioner’s decision because: (1) the ALJ erred in rejecting the opinion of State Agency psychiatric consultant Dr. Peter Sims that Mr. Lawson would miss one to two days of work per month; (2) the Appeals Council erroneously failed to consider

new evidence; and (3) the ALJ did not properly evaluate Mr. Lawson’s subjective pain testimony. The court examines each issue in turn. 1. Dr. Sims’ Opinion

Mr. Lawson’s first argument is that the ALJ erred in rejecting Dr. Sims’ opinion that he would miss one to two days of work per month due to his psychiatric symptoms. (Doc. 16 at 16–17). In February 2020, as part of Mr. Lawson’s request for reconsideration of his

claims at the agency level, Dr. Sims reviewed the evidence in Mr. Lawson’s file and found that he could understand, remember, carry out short and simple instructions, and concentrate for two-hour periods on simple tasks with customary breaks and rest

during the regular workday. (R. at 162–63, 181–82). Dr. Sims also concluded that Mr. Lawson may benefit from a flexible schedule and that Mr. Lawson may miss one to two days of work a month due to his psychiatric signs and symptoms. (Id. at 163, 182). In addition, Dr. Sims explained that Mr. Lawson’s interaction and contact

with the public should be casual; that criticism and feedback from supervisors and co-workers should be casual and non-confronting; and that changes in the workplace should be gradually introduced. (Id. at 163–64, 182–83). In reviewing Dr. Sims’ opinion, the ALJ found that the specific findings that were consistent with unskilled work activity were persuasive because they were

supported by Mr. Lawson’s mental diagnoses and medical history. (R. at 24).

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