Martin v. Commissioner of the Social Security Administration

CourtDistrict Court, D. South Carolina
DecidedAugust 19, 2022
Docket4:21-cv-00483
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. 2022).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION SHAYNE AMBER MARTIN, ) Civil Action No.: 4:21-cv-00483-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 disability insurance benefits(DIB) and 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 DIB in January 2018 and SSI in December 2017, alleging inability to work since November 30, 2016. (Tr. 27). Her claims were denied initially and upon reconsideration. Thereafter, Plaintiff filed a request for a hearing. Plaintiff and a vocational expert (VE) testified at a hearing in January 2020. The Administrative Law Judge (ALJ) issued an unfavorable decision on January 28, 2020, finding that Plaintiff was not disabled within the meaning 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. of the Act. (Tr. 27). Plaintiff filed a request for review of the ALJ’s decision, which the Appeals Council denied in December 2020, making the ALJ’s decision the Commissioner’s final decision. (Tr.1-3). Plaintiff filed an action in this court in February 2021. (ECF No. 1). B. Plaintiff’s Background

Plaintiff was born on April 14, 1975, and was forty-one years old on the alleged onset date. (Tr. 41). Plaintiff had at least a high school education and past work of caseworker, director of a community organization, and masseuse. (Tr. 41). Plaintiff alleges disability originally due to hypoglycemia, bipolar disorder, frequent unconsciousness, liver disease, migraines, headaches, and back problems. (Tr. 94). C. The ALJ’s Decision In the decision of January 2020, the ALJ made the following findings of fact and conclusions

of law (Tr. 27): 1. The claimant meets the insured status requirements of the Social Security Act through December 31, 2021. 2. The claimant has not engaged in substantial gainful activity since November 30, 2016, the alleged onset date (20 CFR 404.1571 et seq., and 416.971 et seq.). 3. The claimant has the following severe impairments: lumbar lordosis, major depressive disorder, generalized anxiety disorder with panic attacks, and post-traumatic stress disorder. (20 CFR 404.1520(c) and 416.920(c)). 4. 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 P, Appendix 1 (20 CFR 404.1520(d), 404.1525, 404.1526, 416.920(d), 416.925 and 416.926). 5. 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 404.1567(b) and 416.967(b) except that she can never climb 2 ladders, ropes, or scaffolds and can occasionally climb ramps and stairs and can occasionally stoop, kneel, crouch, and crawl. She must avoid concentrated exposure to temperature extremes, humidity, and workplace hazards. The claimant is limited to simple and routine tasks with no interaction with the general public. She can work in proximity to but not in coordination with others. 6. The claimant is unable to perform any past relevant work (20 CFR 404.1565 and 416.965). 7. The claimant was born on April 14, 1975 and was 41 years old, which is defined as a younger individual age 18-49, on the alleged disability onset date (20 CFR 404.1563 and 416.963). 8. The claimant has at least a high school education and is able to communicate in English (20 CFR 404.1564 and 416.964). 9. Transferability of job skills is not material to the determination of disability because using the Medical-Vocational Rules as a framework supports a finding that the claimant is “not disabled,” whether or not the claimant has transferable job skills (See SSR 82-41 and 20 CFR Part 404, Subpart P, Appendix 2). 10. 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 404.1569, 404.1569(a), 416.969, and 416.969(a)). 11. The claimant has not been under a disability, as defined in the Social Security Act, from November 30, 2016, through the date of this decision (20 CFR 404.1520(g) and 416.920(g)). II. DISCUSSION Plaintiff argues generally that the ALJ did not perform a proper function by function analysis. Plaintiff argues the ALJ erred in finding hypoglycemia non-severe. Plaintiff argues the RFC does not properly accommodate mental impairments. Plaintiff argues the ALJ did not properly evaluate limitations in concentration, persistence, and pace. Plaintiff argues the ALJ erred in the subjective 3 symptom evaluation. The Commissioner argues that the ALJ’s decision is supported by substantial evidence. A. LEGAL FRAMEWORK 1. The Commissioner’s Determination–of–Disability Process

The Act provides that disability benefits shall be available to those persons insured for benefits, who are not of retirement age, who properly apply, and who are under a “disability.” 42 U.S.C. § 423(a). Section 423(d)(1)(A) defines disability as: the inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for at least 12 consecutive months. 42 U.S.C. § 423(d)(1)(A). To facilitate a uniform and efficient processing of disability claims, regulations promulgated

under the Act have reduced the statutory definition of disability to a series of five sequential questions. See, e.g., Heckler v.

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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-2022.