Ledbetter v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedJune 24, 2025
Docket5:24-cv-01199
StatusUnknown

This text of Ledbetter v. Social Security Administration, Commissioner (Ledbetter 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
Ledbetter v. Social Security Administration, Commissioner, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA NORTHEASTERN DIVISION KIMBERLY LEDBETTER, ) ) Plaintiff, ) ) v. ) Case No.: 5:24-cv-1199-LCB ) SOCIAL SECURITY ) ADMINISTRATION, ) Commissioner, ) ) Defendant. )

MEMORANDUM OPINION

On August 30, 2024, the Claimant, Kimberly Ledbetter, who alleges disability due to debilitating back pain and limitations, 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). (Docs. 1 & 13). The Commissioner filed an answer and a copy of the administrative record on October 29, 2024. (Doc. 6). Ledbetter filed a brief in support of her position on December 30, 2024, and the Commissioner filed a response on March 19, 2025. (Docs. 13 & 21). Ledbetter did not file a reply brief. Accordingly, the issues are now fully briefed, and Ledbetter’s case is ripe for review. For the reasons set forth below, the Commissioner’s final decision is due to be affirmed. I. BACKGROUND On June 9, 2021, Ledbetter protectively filed a Title II application for a period

of disability and disability insurance benefits, alleging disability beginning October 15, 2020. (R. at 15).1 In her claim, Ledbetter alleged her impairments as “spinal stenosis, depression, anxiety, [and] high blood pressure.” Her claim was denied

initially on April 6, 2022 (Id. at 106–10), and upon reconsideration on March 14, 2023 (Id. at 106–15). Thereafter, Ledbetter requested a hearing before an Administrative Law Judge (“the ALJ”). (Id. at 138–39). The ALJ held a virtual hearing on September 12, 2023. (Id. at 30–49). Ledbetter testified at the hearing, as

did an impartial vocational expert (“VE”). (Id.). The ALJ subsequently issued an unfavorable decision. (Id. at 12–29). Ledbetter requested a review of the ALJ’s decision by the Appeals Council. (Id. at 225–27). The Appeals Council affirmed the

ALJ’s decision. (Id. at 1–6). Ledbetter filed a complaint in this Court on August 30, 2024. (Doc. 1). II. THE ALJ’S DECISION To determine whether a claimant is disabled, the ALJ follows a five-step

evaluation process set forth by the Social Security Administration. See 20 CFR 416.920(a). The steps are followed in order and, if it is determined that the claimant

1 The administrative record is attached to Doc. 6 and is Bates numbered. The Court cites to the administrative record as “(R. at [corresponding Bates number]).”. is or is not disabled at any particular step of the evaluation process, the ALJ will not proceed to the next step. After the September 12, 2023, hearing, the ALJ issued a

written opinion explaining the decision. (R. at 12–29). In his decision, the ALJ followed the five-step evaluation process set forth by the Social Security Administration.

The first step requires the ALJ to determine whether the claimant is engaging in substantial gainful activity, which is work involving significant physical or mental activities usually done for pay or profit. Green v. Comm’r, Social Sec. Admin., 555 Fed. App’x 906, 907–08 (11th Cir. 2014). 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 Ledbetter was not engaged in substantial gainful activity during the relevant period. (R. at 17).

Accordingly, the ALJ moved to the second step of the evaluation. At step two, an ALJ must 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 Ledbetter had severe impairments of lumbar spondylolisthesis and obesity. (R. at 17–18) (citing 20 CFR 404.1520(c) and 20 CFR 416.920(c)).2

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 Ledbetter’s impairments did not meet or equal any of the listed criteria and proceeded to step four. (R. at 19) (citing 20 CFR 404.1520(d),

404.1525, 404.1526, 416.925, and 416.926). Step four of the evaluation requires an ALJ to first determine the claimant’s residual functional capacity (“RFC”). 20 CFR 416.920(f). After that, the ALJ must

determine whether a claimant has the RFC to perform the requirements of any past relevant work. Id. 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

2 Medical evidence of record showed Ledbetter also suffered from contact dermatitis, pharyngitis, and hypertension. (R. at 18). The ALJ found that these were not medically determinable impairments. (Id.). The record also showed that Ledbetter suffered from depression, but the ALJ found that this impairment created no more than minimal work-related limitations and, therefore, was a non-severe impairment. (Id.). Thus, the ALJ determined that Ledbetter had only two severe impairments: lumbar spondylolisthesis and obesity. (Id.). Ledbetter does not challenge this finding in her complaint or brief. Thus, the Court limits its discussion to only those severe impairments. evaluation proceeds to the final step. In Ledbetter’s case, the ALJ found that she had the following RFC:

“[T]o perform light work as defined in 20 CFR 404.1567(b) and 416.967(b) except frequent balance, stoop, kneel crouch and crawl, occasionally climbing ramps and stairs, no climbing ladders, ropes or scaffolds, frequent overhead reaching bilaterally, no concentrated exposure to extreme temperatures or vibrations, no working at unprotected heights or unguarded moving machinery.”

(R. at 19). Given this RFC, the ALJ concluded that Ledbetter was unable to perform her past relevant work as a screen printer or inventory clerk. (Id. at 22). However, considering Ledbetter’s RFC and her age, education, and work experience, the ALJ found that there exist a significant number of other jobs in the national economy that Ledbetter could perform. (Id. at 24). The ALJ, adopted the VE’s testimony that based on Ledbetter’s RFC, age, education, and work experience, she could “perform the requirements of representative occupations such as” a router, photocopy machine operator, and marker. (Id.

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