Littlejohn v. Commissioner of the Social Security Administration

CourtDistrict Court, D. South Carolina
DecidedOctober 6, 2021
Docket4:20-cv-02742
StatusUnknown

This text of Littlejohn v. Commissioner of the Social Security Administration (Littlejohn v. Commissioner of the Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, D. South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Littlejohn v. Commissioner of the Social Security Administration, (D.S.C. 2021).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION SMITHA PATRICE LITTLEJOHN, ) Civil Action No.: 4:20-cv-02742-TER ) Plaintiff, ) ) ) -vs- ) ) ORDER Kilolo Kijakazi,1 ) Acting Commissioner of Social Security, ) ) Defendant. ) ___________________________________ ) This is an action brought pursuant to Section 205(g) of the Social Security Act, as amended, 42 U.S.C. Section 405(g), to obtain judicial review of a “final decision” of the Commissioner of Social Security, denying Plaintiff’s claim for supplemental security income (SSI). The only issues before the Court are whether the findings of fact are supported by substantial evidence and whether proper legal standards have been applied. This action is proceeding before the undersigned pursuant to 28 U.S.C. § 636(c) and Fed. R. Civ. Proc. R. 73. I. RELEVANT BACKGROUND A. Procedural History Plaintiff filed an application for SSI on April 10, 2018, alleging inability to work since March 11, 2017. (Tr. 209). Her claims were denied initially and upon reconsideration. Thereafter, Plaintiff filed a request for a rehearing. A hearing was held on July 19, 2019, at which time Plaintiff and a vocational expert (VE) testified. The Administrative Law Judge (ALJ) issued an unfavorable 1 Kilolo Kijakazi is the Acting Commissioner of Social Security. Pursuant to Fed. R. Civ. P. 25(d), she is automatically substituted for Defendant Andrew Saul who was the Commissioner of Social Security when this action was filed. decision on August 27, 2019, finding that Plaintiff was not disabled. (Tr. 22-36). Plaintiff filed a request for review of the ALJ’s decision, which the Appeals Council denied on June 22, 2020, making the ALJ’s decision the Commissioner’s final decision. (Tr. 1-4). Plaintiff filed this action on July 27, 2020. (ECF No. 1).

B. Plaintiff’s Background and Medical History Plaintiff was born on February 17, 1980, and was thirty-eight years old at the time the application was filed. (Tr. 33, 209). Plaintiff alleges disability originally due to lupus, high blood pressure, depression, carpal tunnel, low potassium, acid reflux, and allergies/bronchitis.2 (Tr. 125). Pertinent medical records will be summarized under the relevant headings. C. The ALJ’s Decision In the decision of August 27, 2019, the ALJ made the following findings of fact and

conclusions of law (Tr. 25-36): 1. The claimant has not engaged in substantial gainful activity since April 10, 2018, the application date (20 CFR 416.971 et seq.). 2. The claimant has the following severe impairments: systemic lupus erythematosus (SLE); left ulnar entrapment; respiratory disorder with ongoing tobacco abuse and obesity (20 CFR 416.920(c)). 3. The claimant does not have an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments in 20 CFR Part 404, Subpart 2 Plaintiff had previously filed for disability and disability insurance benefits and received an administratively final unfavorable decision in March 2017. (Tr. 83-96). Plaintiff’s appeal of that decision was denied in January 2018. (Tr. 102-05). An earlier determination at any stage in the administrative process may be final-and, thus, binding on subsequent claims-unless the claimant seeks timely review at the next stage. See, e.g., McGowen v. Harris, 666 F.2d 60, 65 (4th Cir.1981). Where not reopened, findings on a prior application are conclusive as to that period. 20 C.F.R. 404.987; McCoy on Behalf of McCoy v. Chater, 81 F.3d 44, 46 (6th Cir. 1995)(the only relevant evidence was plaintiff's condition after the administratively final decision). 2 P, Appendix 1 (20 CFR 416.920(d), 416.925 and 416.926). 4. After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform light work as defined in 20 CFR 416.967(b). Specifically, over the course of an eight-hour workday, in two hour increments with normal and acceptable work breaks, the claimant can occasionally climb ladders, ropes, and scaffolds, climb ramps and stairs, kneel, crouch, and crawl. The claimant can frequently balance and stoop. Handling can be performed frequently on the nondominant left upper extremity within the exertional level and bilateral fingering can be performed frequently. She can occasionally be exposed to extreme cold, extreme heat, excessive humidity, pulmonary irritants (such as fumes, smoke, odors, dust, gases and poor ventilation), and unprotected hazards associated with unprotected dangerous machinery or unprotected heights. Due to the effects of pain, fatigue, and medications, the claimant can concentrate, persist and maintain pace to understand, remember and carry out unskilled, routine tasks, in a low stress work environment (defined as being free of fast-paced or team dependent production requirements), involving the application of commonsense understanding to carry out instructions furnished in written, oral, or diagrammatic form. She can deal with problems involving several concrete variables in or from standardized situations. The claimant can adapt to occasional workplace changes. 5. The claimant is unable to perform any past relevant work (20 CFR 416.965). 6. The claimant was born on February 17, 1980 and was 38 years old, which is defined as a younger individual age 18-49, on the date the application was filed (20 CFR 416.963). 7. The claimant has at least a high school education and is able to communicate in English (20 CFR 416.964). 8. Transferability of job skills is not an issue in this case because the claimant’s past relevant work is unskilled (20 CFR 416.968). 9. Considering the claimant’s age, education, work experience, and residual functional capacity, there are jobs that exist in significant numbers in the national economy that the claimant can perform (20 CFR 416.969 and 416.969a). 10. The claimant has not been under a disability, as defined in the Social Security Act, since April 10, 2018, the date the application was filed (20 CFR 416.920(g)). II. DISCUSSION Plaintiff argues that the ALJ erred in failing to discuss the findings of the ALJ from her previous social security matter and in determining the RFC. Defendant argues substantial evidence 3 supports the ALJ’s decision. A. LEGAL FRAMEWORK 1.

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Bluebook (online)
Littlejohn v. Commissioner of the Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/littlejohn-v-commissioner-of-the-social-security-administration-scd-2021.