Martin v. Commissioner of the Social Security Administration

CourtDistrict Court, D. South Carolina
DecidedAugust 31, 2020
Docket5:19-cv-00898
StatusUnknown

This text of Martin v. Commissioner of the Social Security Administration (Martin 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
Martin v. Commissioner of the Social Security Administration, (D.S.C. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF SOUTH CAROLINA ORANGEBURG DIVISION

Deana Martin, Civil Action No. 5:19-cv-898-CMC

Plaintiff, vs. OPINION AND ORDER

Andrew M. Saul,1 Commissioner of Social Security Administration, Defendant.

Following the adverse final decision of the Commissioner of Social Security (“Commissioner”) denying her claim for Disability Insurance Benefits (“DIB”), Plaintiff filed a complaint on March 25, 2019, seeking judicial review of the Commissioner’s decision pursuant to 42 U.S.C. § 405(g). ECF No. 1. The matter was referred to a United States Magistrate Judge for a report and recommendation. See 28 U.S.C. § 636(b)(1)(B) (authorizing the district court to, among other things, direct a magistrate judge to submit a report to the district court with proposed “recommendations for the disposition” of a pending matter); D.S.C. Local Rule 83.VII.02(A) (noting after the briefing schedule is established in social security cases, “the case will be referred to a magistrate judge for either a recommendation or a final order, dependent upon the consent of the parties and the district court”). On April 20, 2020, Magistrate Judge Kaymani D. West issued a report and recommendation (“Report”), recommending the Commissioner’s decision be affirmed. ECF No. 17.

1 Andrew M. Saul was sworn in as Commissioner of Social Security on June 18, 2019, replacing Acting Commissioner, Nancy A. Berryhill. On May 14, 2020, Plaintiff filed objections to the Report, ECF No. 19, to which the Commissioner filed a reply on May 26, 2020. ECF No. 20. For the reasons stated below, the court adopts the Report and affirms the decision of the Commissioner. Standard 1) Court’s Review of Magistrate Judge’s Report and Recommendation

A magistrate judge only makes a recommendation to the court. Mathews v. Weber, 423 U.S. 261, 270 (1976). Such recommendation is afforded no “presumptive weight,” which necessarily leaves the “authority and the responsibility [of] mak[ing] an informed, final determination” with the court. Id. at 271. Within fourteen days after being served with the magistrate judge’s report and recommendation, any party may object to the recommendation.2 28 U.S.C. § 636(b)(1). If a timely objection is filed, the court must make a de novo determination of those portions of the recommendation to which objection is made. Id. After conducting this de novo review, the court may accept, reject, or modify, in whole or in part, the recommendation of the magistrate judge, or

recommit the matter to the magistrate judge with instructions. Id. In the absence of an objection, the court may accept the recommendation of the magistrate judge provided a review of the record reveals no clear error.3 Diamond v. Colonial Life & Acc. Ins. Co., 416 F.3d 310, 315 (4th Cir. 2005).

2 A party’s objection must be made with “sufficient specificity so as reasonably to alert the district court of the true ground for the objection.” United States v. Midgette, 478 F.3d 616, 622 (4th Cir 2007).

3 When a party receives notice of the consequences of failing to comply with the timely objection filing requirement, the failure to file a timely objection results in a waiver of that objection in the Footnote Continued . . . 2 2) Court’s Review of Agency Decision The court is authorized to review the Commissioner’s denial of DIB under 42 U.S.C. § 405(g). Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001). Such review neither involves a trial de novo, Vitek v. Finch, 438 F.2d 1157, 1157 (4th Cir. 1971), nor a de novo review of the evidence, Smith v. Schweiker, 795 F.2d 343, 345 (4th Cir. 1986). Rather, the court’s review is “narrow,” id.,

and is limited to whether the Commissioner’s factual findings are supported by substantial evidence and whether the Commissioner applied the correct legal standards. Walls v. Barnhart, 296 F.3d 287, 290 (4th Cir. 2002). “The phrase ‘substantial evidence’ is a ‘term of art’ used throughout administrative law to describe how courts are to review agency factfinding.” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (quoting T-Mobile South, LLC v. Roswell, 135 S. Ct. 808, 815 (2015)). In applying the substantial evidence standard, the “court looks to an existing administrative record and asks whether it contains ‘sufficien[t] evidence’ to support the agency’s factual determinations.” Id. (alteration marks in original) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229

(1938)). The “evidentiary sufficiency” necessary to meet this standard is “not high.” Id. Substantial evidence, the Fourth Circuit has said, “consists of more than a mere scintilla of evidence but may be less than a preponderance.” Smith v. Chater, 99 F.3d 635, 638 (4th Cir. 1996). “It means—and means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Biestek, 139 S. Ct. at 1154 (quoting Consolidated Edison Co., 305 U.S. at 229).

court of appeals. Diamond, 416 F.3d at 315–16; Wells v. Shriners Hosp., 109 F.3d 198, 201 (4th Cir. 1997); Wright v. Collins, 766 F.2d 841, 845–46 (4th Cir. 1985). 3 Although considerable deference is afforded to the Commissioner’s factfinding, the court does not “mechanically accept[]” his findings. Flack v. Cohen, 413 F.2d 278, 279 (4th Cir. 1969). Rather, the “statutorily granted right of review contemplates more than an uncritical rubber stamping of the administrative action.” Id. Indeed, “courts must not abdicate their responsibility to give careful scrutiny to the whole record to assure that there is a sound foundation for the

[Commissioner’s] findings, and that his conclusion is rational.” Vitek, 438 F.2d at 1157-58. Along a similar vein, to meaningfully perform substantial evidence review, the record must set forth the basis for the Commissioner’s decision. Radford v. Colvin, 734 F.3d 288, 295 (4th Cir. 2013). The Commissioner’s decision “should include a discussion of which evidence [he] found credible and why, and specific application of the pertinent legal requirements to the record evidence.” Id.; see also 42 U.S.C. § 405(b)(1) (noting the Commissioner’s decision must “contain a statement of the case, in understandable language, setting forth a discussion of the evidence, and stating the Commissioner’s determination and the reason or reasons upon which it is based”). Put another way, the Commissioner’s decision must identify the evidence that supports his conclusion

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Securities & Exchange Commission v. Chenery Corp.
318 U.S. 80 (Supreme Court, 1943)
Mathews v. Weber
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Heckler v. Edwards
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Allen v. Barnhart
357 F.3d 1140 (Tenth Circuit, 2004)
Spiva v. Astrue
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Meyer v. Astrue
662 F.3d 700 (Fourth Circuit, 2011)
Harold Wells Richard Oeland v. Shriners Hosptial
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Martin v. Commissioner of the Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/martin-v-commissioner-of-the-social-security-administration-scd-2020.