Linn v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedMarch 17, 2025
Docket1:23-cv-01520
StatusUnknown

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

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA EASTERN DIVISION

JOHN DAVID LINN, JR., ) ) Plaintiff ) ) vs. ) Case No. 1:23-cv-01520-HNJ ) SOCIAL SECURITY ADMINISTRATION, ) COMMISSIONER, ) ) Defendant. )

MEMORANDUM OPINION

Plaintiff John David Linn, Jr., seeks judicial review pursuant to 42 U.S.C. § 405(g) of an adverse, final decision of the Commissioner of the Social Security Administration (“Commissioner”), regarding the termination of his disability insurance benefits. The undersigned carefully considered the record, and for the reasons expressed herein, AFFIRMS the Commissioner’s decision.1 LAW AND STANDARD OF REVIEW To qualify for disability benefits, the claimant must be disabled as defined by the Social Security Act and the Regulations promulgated thereunder. The Regulations define “disabled” as the “inability to do any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result

1 In accordance with the provisions of 28 U.S.C. § 636(c) and Federal Rule of Civil Procedure 73, the parties have voluntarily consented to have a United States Magistrate Judge conduct any and all proceedings, including the entry of final judgment. (Doc. 16). in death or which has lasted or can be expected to last for a continuous period of not less than twelve (12) months.” 20 C.F.R. § 404.1505(a). To establish an entitlement to

disability benefits, a claimant must provide evidence of a “physical or mental impairment” which “results from anatomical, physiological, or psychological abnormalities which are demonstrable by medically acceptable clinical and laboratory diagnostic techniques.” 42 U.S.C. § 423(d)(3).

If a claimant qualifies for and receives disability benefits, the Commissioner must periodically review the claimant’s disability to ascertain whether the claimant remains entitled to benefits. See 20 C.F.R. § 404.1594(a). In determining whether a claimant continues to suffer a disability, and thus remains entitled to benefits, the Commissioner,

through an Administrative Law Judge (ALJ), works through an eight-step sequential evaluation process. See 20 C.F.R. § 404.1594(f). The burden rests upon the Commissioner to prove the cessation of the claimant’s disability. See Imfield v. O’Malley, No. 8:23-CV-1071-JRK, 2024 WL 4284981, at *3 (M.D. Fla. Sept. 25, 2024); Fleck v.

Colvin, No. 5:15-CV-01293-MHH, 2016 WL 8671769, at *1 (N.D. Ala. Sept. 30, 2016). In the first step of the eight-step sequential process, the claimant cannot be currently engaged in substantial gainful activity. 20 C.F.R. §§ 404.1594(f)(1).

At step two, the evaluator must conclude the claimant’s disability continues if he or she suffers an impairment or a combination of impairments which meets or medically equals one of the impairments listed at 20 C.F.R. Part 404, Subpart P, Appendix 1, §§ 1.00-114.02. Id. § 404.1594(f)(2). If the claimant’s impairment or combination of impairments does not meet or medically equal a listed impairment, the evaluator determines at step three whether the

claimant exhibits medical improvement. Id. § 404.1594(f)(3). Medical improvement constitutes “any decrease in the medical severity of [the claimant’s] impairment(s) . . . present at the time of the most recent favorable medical decision” finding the claimant disabled. Id. § 404.1594(b)(1). A finding of medical improvement

properly relies upon “improvement in the symptoms, signs and/or laboratory findings associated with [the claimant’s] impairment(s).” Id. § 404.1594(b)(1). If the claimant exhibits medical improvement, at step four the evaluator must determine whether the medical improvement increases the claimant’s residual

functional capacity (“RFC”) to perform work. Id. § 404.1594(f)(4). At step five, the evaluator will find the claimant’s disability continues – subject to certain exceptions2 – if the claimant fails to exhibit medical improvement, or if the

2 Pursuant to § 404.1594(e), the evaluator will find the claimant not disabled if: (1) “any prior favorable decision was obtained by fraud”; (2) “without good cause,” the claimant fails to provide requested “medical or other evidence or to go for a physical or mental examination by a certain date”; (3) the Commissioner cannot locate the claimant to resolve a question regarding his or her disability; or (4) the claimant “fail[s] to follow prescribed treatment which would be expected to restore [the] ability to engage in substantial gainful activity.” 20 C.F.R. § 404.1594(e).

Pursuant to § 404.1594(d), the evaluator must consider whether: (1) “[s]ubstantial evidence shows that [the claimant] [is] the beneficiary of advances in medical or vocational therapy or technology (related to [the] ability to work)”; (2) “[s]ubstantial evidence shows that [the claimant] has undergone vocational therapy (related to [the] ability to work)”; (3) “[s]ubstantial evidence shows that based on new or improved diagnostic or evaluative techniques [the claimant’s] impairment(s) is not as disabling as it was considered to be at the time of the most recent favorable decision”; or (4) “[s]ubstantial evidence demonstrates that any prior disability decision was in error.” 20 C.F.R. § 404.1594(d). If the evaluator determines any of these enumerated exceptions applies to the claimant, the evaluator will proceed to steps five and six of the sequential processes. 20 C.F.R. § 404.1594(f)(5). claimant exhibits medical improvement that does not increase his or her RFC. 20 C.F.R. § 404.1594(f)(5).

If the claimant exhibits medical improvement that increases his or her RFC, or if the evaluator finds that a § 404.1594(d) exception applies to the claimant, the evaluator determines at step six whether the claimant’s impairments manifest as severe based upon “all . . . current impairments and the impact of those impairments on [the

claimant’s] ability to function.” Id. § 404.1594(f)(6). If the claimant’s impairments do not manifest as severe, the evaluator will conclude the claimant’s disability ceased. Id. § 404.1594(f)(6). If the claimant’s impairments manifest as severe, the evaluation proceeds to the

seventh step, where the evaluator assesses whether the claimant retains the ability to perform past work. Id. § 404.1594(f)(7). If the claimant retains the ability to perform past work, the evaluator will determine the claimant’s disability ceased. Id. § 404.1594(f)(7).

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