McBride v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedAugust 19, 2022
Docket5:20-cv-02045
StatusUnknown

This text of McBride v. Social Security Administration, Commissioner (McBride 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
McBride v. Social Security Administration, Commissioner, (N.D. Ala. 2022).

Opinion

U.S. DISTRICT. N.D. OF AL IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA NORTHEASTERN DIVISION WILLIAM MCBRIDE, ) ) Plaintiff, ) ) VS. ) Civil Action No. ) 5:20-CV-02045-LSC KILOLO KIJJAKAZI, Acting ) Commissioner of Social Security, ) ) Defendant. ) MEMORANDUM OF OPINION I. Introduction The plaintiff, William McBride (“ McBride” or “ Plaintiff”), appeals from the decision of the Commissioner of the Social Security Administration (“Commissioner”) denying his application for Supplemental Security Income (“SSI”). McBride timely pursued and exhausted his administrative remedies and the decision of the Commissioner is ripe for review pursuant to 42 U.S.C. §§ 405(g), 1383(c)(3). McBride was 20 years old at the time of the Administrative Law Judge’s (“ALJ’s”) decision, and he has a high school education. (See Tr. 26, 36, 154,). Plaintiff has no previous relevant work. (Tr. 24, 36). Plaintiff claims to have been disabled beginning February 12, 2000, due to autism spectrum disorder (“ASD”),

attention deficit hyperactive disorder (“ADHD”), sleep apnea, an unspecified learning disability, and low average IQ, (Tr. 158). The Social Security Administration has established a five-step sequential evaluation process for determining whether an individual is disabled and thus eligible for disability insurance benefits (“DIB”) or SSI. See 20 C.F.R. §§ 404.1520, 416.920; see also Doughty v. Apfel, 245 F.3d 1274, 1278 (11th Cir. 2001). The evaluator will follow the steps in order until making a finding of either disabled or not disabled; if no finding is made, the analysis will proceed to the next step. See 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4). The first step requires the evaluator to determine whether the plaintiff is engaged in substantial gainful activity (“SGA”). Jd. §§ 404.1520(a)(4)(i), 416.920(a)(4)(i). If the plaintiff is not engaged in SGA, the evaluator moves on to the next step. The second step requires the evaluator to consider the combined severity of the plaintiff’s medically determinable physical and mental impairments. Jd. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). An individual impairment or combination of impairments that is not classified as “severe” and does not satisfy the durational requirements set forth in 20 C.F.R. §§ 404.1509 and 416.909 will result in a finding of not disabled. /d. The decision depends on the medical evidence contained in the record. See Hart v. Finch, 440 F.2d 1340, 1341 (5th Cir. 1971) (concluding that

“substantial medical evidence in the record” adequately supported the finding that the plaintiff was not disabled). Similarly, the third step requires the evaluator to consider whether the plaintiff’s impairment or combination of impairments meets or is medically equal to the criteria of impairment listed in 20 C.F.R. Part 404, Subpart P, Appendix 1. 20 C.F.R. §§ 404.1520(a)(4) (ili), 416.920(a)(4) (iii). If the criteria of a listed impairment and the durational requirements set forth in 20 C.F.R. §§ 404.1509 and 416.909 are satisfied, the evaluator will make a finding of disabled. Jd. If the plaintiffs impairment or combination of impairments does not meet or medically equal a listed impairment, the evaluator must determine the plaintiff’s residual functional capacity (“RFC”) before proceeding to the fourth step. See ad. §§ 404.1520(e), 416.920(e). The fourth step requires the evaluator to determine whether the plaintiff has the RFC to perform the requirements of her past relevant work. See zd. §§ 404.1520(a)(4)(iv), 416.920(a)(4)(iv). If the plaintiff’s impairment or combination of impairments does not prevent her from performing her past relevant work, the evaluator will make a finding of not disabled. See zd. The fifth and final step requires the evaluator to consider the plaintiff?s RFC,

age, education, and work experience in order to determine whether the plaintiff can make an adjustment to other work. Jd. §§ 404.1520(a)(4)(v), 416.920(a)(4)(v). If the

plaintiff can perform other work, the evaluator will find her not disabled. /d.; see also

20 C.F.R. §§ 404.1520(g), 416.920(g). If the plaintiff cannot perform other work, the evaluator will find her disabled. 20 C.F.R. §§ 404.1520(a)(4)(v), 404.1520(g), 416.920(a)(4)(v), 416.920(g). Applying the sequential evaluation process, the ALJ found that McBride has

not engaged in SGA since December 3, 2018. (Tr. 16.) According to the ALJ, the plaintiffs ADHD, anxiety disorder, and learning disorder are severe impairments (Tr. 16.) However, the ALJ found that these impairments neither meet nor medically equal any of the listed impairments in 20 C.F.R. Part 404, Subpart P, Appendix 1. (Tr. 18.) The ALJ determined that Plaintiff has the following RFC: [To perform a full range of work at all exertional levels but with the following nonexertional limitations: The claimant would be able to understand, remember and carry out short simple instructions and tasks, and also able [to] maintain attention and concentration for two hours at a time sufficient to complete an eight-hour work day. Contact with the general public should be infrequent and non-intensive. Changes in the workplace should be infrequent and gradually introduced. (Tr. at 20.) According to the ALJ, the Plaintiff has no relevant past work according to the definition in 20 C.F.R. § 416.965. (Tr. 24.) The ALJ also determined that the plaintiff was a “younger individual age 18-49” at 18 years old, has at least a high school education, and is able to communicate in English, as those terms are defined

by the regulations. (Tr. 24-25.) The ALJ determined that the “transferability of job skills is not an issue because the claimant does not have past relevant work.” (Tr. 25.) Because the ALJ determined that Plaintiff had some nonexertional limitations, the ALJ enlisted a vocational expert (“VE”) and used Medical-Vocation Rules as a guideline for finding that there are a significant number of jobs in the national

economy that the plaintiff is capable of performing, such as stacker, assembler, laundry worker, tagger, bagger, and hand bander. (/d.) The ALJ concluded her findings by stating that Plaintiff “has not been under a disability, as defined in the Social Security Act, since December 3, 2018, the date the application was filed.” (Tr. 26.) II. Standard of Review This court’s role in reviewing claims brought under the Social Security Act 1s

a narrow one.

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McBride v. Social Security Administration, Commissioner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mcbride-v-social-security-administration-commissioner-alnd-2022.