Mayo v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedMarch 28, 2025
Docket4:24-cv-00025
StatusUnknown

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

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA MIDDLE DIVISION

DONNA MAYO, } } Plaintiff, } } v. } Case No. 4:24-cv-00025-SLB } LELAND DUDEK, } Acting Commissioner, } Social Security Administration, } } Defendant. }

MEMORANDUM OPINION

Plaintiff Donna Mayo appeals the decision of the Commissioner of Social Security denying her Title II application for a period of disability and disability insurance benefits. Based on the court's review of the administrative record and the parties’ briefs, the court WILL AFFIRM the Commissioner's decision. I. STANDARD OF REVIEW The court's role in reviewing claims brought under the Social Security Act is a narrow one. The court “must determine whether the Commissioner's decision is supported by substantial evidence and based on proper legal standards.” Winschel v. Comm'r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011) (quotation marks omitted). “Under the substantial evidence standard, this court will affirm the ALJ's decision if there exists such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Henry v. Comm'r of Soc. Sec., 802 F.3d 1264, 1267 (11th Cir. 2015) (quotation marks omitted). The court “may not decide the facts

anew, reweigh the evidence, or substitute [its] judgment for that of the [ALJ].” Winschel, 631 F.3d at 1178 (quotation marks omitted). The court must affirm “[e]ven if the evidence preponderates against the Commissioner's findings.” Crawford v.

Comm'r of Soc. Sec., 363 F.3d 1155, 1158–59 (11th Cir. 2004) (quotation marks omitted). Despite the deferential standard for review of claims, the court “must

scrutinize the record as a whole to determine if the decision reached is reasonable and supported by substantial evidence.” Henry, 802 F.3d at 1267 (quotation marks omitted). Moreover, the court must reverse the Commissioner's decision if the ALJ

does not apply the correct legal standards. Cornelius v. Sullivan, 936 F.2d 1143, 1145–46 (11th Cir. 1991).

II. PROCEDURAL HISTORY Donna Mayo applied for a period of disability and disability insurance benefits in September 2021. (Doc. 5 at R. 315).1 Ms. Mayo stated her disability

began October 1, 2018. (Id.). The agency found she was not disabled. (Id. at 115). On reconsideration, the agency again denied her claim stating, “the evidence does

1 Reference to a document number, [“Doc. ___”], refers to the number assigned to each document as it is filed in the court’s record. not suggest an impairment that would meet or equal a listing.” (Id. at 124). Following the denial, Ms. Mayo requested a hearing before an ALJ. (Id. at 197). After the

hearing, the ALJ determined Ms. Mayo to be disabled and issued a favorable decision. (Id. at 129). Following review on its own motion of the ALJ’s decision, the Appeals Council vacated the decision and remanded Ms. Mayo’s case to an ALJ for

further review. (Id. at 10). In its remand order, the Appeals Council directed the ALJ to:

Obtain additional evidence concerning the claimant’s impairments in order to complete the administrative record in accordance with the regulatory standards regarding consultative examinations and existing medical evidence;

Give further consideration to the claimant’s severe, medically determinable impairments during the relevant period at issue, including evaluation of fibromyalgia;

Reassess the claimant’s maximum residual functional capacity throughout the period at issue and provide rationale with specific references to the evidence of record in support of the assessed limitations;

Obtain supplemental evidence from a vocational expert to clarify the effect of the reassessed limitations on the claimant’s occupational base; and

In compliance with the above, offer the claimant an opportunity for a hearing, take any further action needed to complete the administrative record and issue a new decision.

(Id.). The second ALJ held a telephone hearing on June 13, 2023. (Id.). After consideration of Ms. Mayo’s testimony and a review of the entire record, the ALJ determined Ms. Mayo was not disabled under sections 216(i) and 223(d) of the Social Security Act. (Id. at 23). Ms. Mayo then requested the Appeals Council review

the ALJ’s decision, which was subsequently denied. (Id. at 1-6). The Commissioner’s decision is now final, and Ms. Mayo’s appeal is fully briefed and ripe for judicial review. See, 42 U.S.C. § 405(g).

III. THE SECOND ALJ DECISION

As a court may only review the final decision of the Commissioner under 42 U.S.C. § 405(g), this court must determine only whether the record supports the decision of the second ALJ. Social security regulations require that disability is determined under a five-step evaluation process. To determine whether a claimant

qualifies for disability, the ALJ must evaluate: (1) whether the claimant is currently engaged in substantial gainful activity; (2) whether the claimant has a severe impairment or combination of impairments; (3) whether the impairment meets or equals the severity of the specified impairments in the Listing of Impairments; (4) based on a residual functional capacity (“RFC”) assessment, whether the claimant can perform any of his or her past relevant work despite the impairment; and (5) whether there are significant numbers of jobs in the national economy that the claimant can perform given the claimant's RFC, age, education, and work experience.

Winschel, 631 F.3d at 1178; 20 C.F.R. §§ 416.920(a)(4)(i)-(v). At the time of her hearing, Ms. Mayo was 53 years of age and testified she last worked in October of 2018 as a housekeeper in a nursing home. (Doc. 5 at R.

43-44). Ms. Mayo submitted additional medical evidence for consideration not previously evaluated by the first ALJ or the Appeals Council. (Id. at 41-42). Following the hearing, the ALJ found that Ms. Mayo had not engaged in substantial

gainful activity since the alleged onset date. (Id. at 13). The ALJ determined Ms. Mayo suffered from the following severe impairments that “significantly limit [her] ability to perform basic work activities”: degenerative disc disease, obesity, depression, and anxiety. (Id.). Additionally, the ALJ noted Ms. Mayo’s medical

records reflected diagnoses of hypertension, hyperlipidemia, migraines, gastroesophageal reflux disease, supraventricular tachycardia, a status post fracture of 5th metatarsal bone of the right foot, chronic bronchitis, and insomnia. (Id.). The

ALJ found these conditions to be non-severe impairments because Ms. Mayo had “not demonstrated ongoing or continuous restrictions due to these conditions, and the medical record indicates that they are generally well controlled and non- symptomatic.” (Id.).

The Appeal’s Council specifically requested an evaluation of Ms. Mayo’s fibromyalgia. (Id. at 10). If a claimant alleges fibromyalgia as an impairment,

“unique issues arise . . . [because] [f]ibromyalgia ‘often lacks medical or laboratory signs, and is generally diagnosed mostly on [the claimant’s] described symptoms.’” Horowitz v. Comm’r of Soc.

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