McGranahan v. Commissioner of Social Security

CourtDistrict Court, M.D. Florida
DecidedMarch 8, 2023
Docket8:22-cv-00795
StatusUnknown

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

Bluebook
McGranahan v. Commissioner of Social Security, (M.D. Fla. 2023).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

LISA AMBROSE MCGRANAHAN, . Plaintiff, Vv. Case No. 8:22-cv-795-WJF-TGW KILOLO KIJAKAZI, . Acting Commissioner of Social Security,! . Defendant. . □

REPORT AND RECOMMENDATION The plaintiff seeks judicial review of the denial of her claims for Social Security disability benefits and supplemental security income

payments.” I recommend that the decision of the Acting Commissioner of □ -

Social Security be affirmed because it is supported by substantial evidence and does not contain reversible error. I.

The plaintiff, who was fifty-five years old at the time of the - administrative hearing and who has a high school education, has worked as

'Kilolo Kijakazi became the Acting Commissioner of Social Security on July 9, 2021, and should be substituted as the defendant. See Fed. R. Civ. P. 25(d). 2 This matter comes before the undersigned pursuant to the Standing Order of this. court dated January 5, 1998.

a bookkeeper, bookkeeping/accounting clerk, and financial aid officer (Tr. 30, 44, 335). She filed claims for Social Security disability benefits and supplemental security income payments, alleging that she became disabled

due to major depression disorder, generalized anxiety disorder, and social anxiety disorder (Tr. 335). The claims were denied initially and upon reconsideration. . The plaintiff, at her request, received a de novo hearing before

an administrative law judge. The law judge found that the plaintiff had severe impairments of moderate major depression and generalized anxiety disorder with social anxiety disorder (Tr. 23). The law judge determined that, with those impairments, the plaintiff had residual functional capacity (Tr. 26): to perform a full range of work at all exertional _ levels, but with the following nonexertional limitations: can understand and carryout routine, repetitive, unskilled tasks with the ability to make basic decisions and adjust to simple changes in a work setting; as long as interaction with the public, coworkers and supervisors is no more than ~ frequent. The law judge concluded, based on the testimony of a

vocational expert, that the plaintiff was unable to perform her past relevant

work (Tr. 30). However, in light of the vocational expert’s testimony, the law judge determined that the plaintiff could perform other jobs that exist in significant numbers in the national economy, such as laundry worker,

hospital cleaner, and dining room attendant (Tr. 31-32). Consequently, the law judge found that the plaintiff was not disabled (Tr. 32). The Appeals Council let that decision stand as the final decision of the Commissioner. I. In order to be entitled to Social Security disability benefits and

supplemental security income, a claimant must be unable “to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which ... has lasted or can be expected to last for a continuous period of not less than twelve months.” 42 U.S.C. 423(d)(1)(A), 1382c(a)(3)(A). A “physical or mental impairment,” under the terms of the

Social Security Act, is one “that results from anatomical, physiological, or psychological abnormalities which are demonstrable by medically acceptable clinical and laboratory diagnostic techniques.” 42 U.S.C. 423(d)(3), 1382c(a)(3)(D). A determination by the Commissioner that a claimant is not disabled must be upheld if it is supported by substantial evidence. 42 U.S.C. 405(g). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971), quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938). Under the substantial evidence test, “findings of fact

made by administrative agencies ... may be reversed ... only when the record compels a reversal; the mere fact that the record may support a contrary conclusion is not enough to justify a reversal of the administrative findings.” Adefemi v. Ashcroft, 386 F.3d 1022, 1027 (11th Cir. 2004). It is, moreover, the function of the Commissioner, and not the

courts, to resolve conflicts in the evidence and to assess the credibility of the witnesses. Grant v. Richardson, 445 F.2d 656 (5th Cir. 1971). Similarly, it is the responsibility of the Commissioner to draw inferences from the evidence, and those inferences are not to be overturned if they are supported by substantial evidence. Celebrezze v. O’Brient, 323 F.2d 989, 990 (Sth Cir. 1963). Therefore, in determining whether the Commissioner’s

decision is supported by substantial evidence, the court is not to reweigh the evidence, but is limited to determining whether the record as a whole contains sufficient evidence to permit a reasonable mind to conclude that the □

claimant is not disabled. However, the court, in its review, must satisfy itself that the proper legal standards were applied and legal requirements were met. Lamb v. Bowen, 847 F.2d 698, 701 (1 Ith Cir. 1988).

IL. The plaintiff asserts three arguments: that the law judge (1) “failed to properly evaluate the medical opinion evidence and failed to properly determine [her] mental residual functional capacity based on the medical evidence”; (2) “failed to properly evaluate [her] testimony”; and (3) “relied on a flawed hypothetical question to the vocational expert” (Doc. 10, pp. 17, 28, 32). None of these arguments is meritorious. A. As acknowledged by the plaintiff, the new regulations governing the assessment of medical opinion evidence apply. Those regulations change established principles in the Eleventh Circuit concerning the evaluation of medical opinions. Courts reviewing claims under our current rules have focused more on whether we sufficiently articulated the weight we gave treating source Opinions, rather than on whether substantial evidence supports our final decision. As the Administrative Conference of the United States’ (ACUS) Final Report explains, these courts, in reviewing final agency decisions, are reweighing evidence instead of applying the substantial evidence standard of review, which is intended to be highly deferential standard to us. .

Revision to Rules Regarding the Evaluation of Medical Evidence, 82 Fed. Reg. 5844-01, 5853, 2017 WL 168819 (Jan. 18, 2017). Accordingly, the □ regulations now state (20 C.F.R. 404.1520c¢(a), 416.920c(a)): .

5 -

We will not defer or give any specific evidentiary weight, including controlling weight, to any medical opinions(s) or prior administrative medical finding(s), including those from your medical sources. Rather, medical opinions and prior administrative medical findings are tobe considered for their persuasiveness based upon the following factors:

(1) Supportability (2) Consistency .

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