Merrick v. Commissioner of Social Security

CourtDistrict Court, M.D. Florida
DecidedMarch 17, 2021
Docket8:19-cv-01495
StatusUnknown

This text of Merrick v. Commissioner of Social Security (Merrick 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.

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Merrick v. Commissioner of Social Security, (M.D. Fla. 2021).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

TIMOTHY T. MERRICK,

Plaintiff,

v. CASE NO. 8:19-cv-1495-MCR

COMMISSIONER OF THE SOCIAL SECURITY ADMINISTRATION,

Defendant. __________________________________/

MEMORANDUM OPINION AND ORDER1

THIS CAUSE is before the Court on Plaintiff’s appeal of an administrative decision regarding the issue of overpayment of disability insurance benefits (“DIB”). Following an administrative hearing held on March 8, 2018, the assigned Administrative Law Judge (“ALJ”) issued a decision on June 20, 2018, finding that Plaintiff was overpaid DIB in the amount of $65,720.50 for the period of November 30, 2011 through August 31, 2015, and that Plaintiff was at fault for causing the overpayment. (Tr. 15-18, 331-63.) Plaintiff has exhausted his available administrative remedies and the case is properly before the Court. Based on a review of the record, the briefs, and the applicable law, the Commissioner’s decision is

1 The parties consented to the exercise of jurisdiction by a United States Magistrate Judge. (Doc. 24.) AFFIRMED. I. Standard of Review

The scope of this Court’s review is limited to determining whether the Commissioner applied the correct legal standards, McRoberts v. Bowen, 841 F.2d 1077, 1080 (11th Cir. 1988), and whether the Commissioner’s findings are supported by substantial evidence, Richardson v. Perales, 402 U.S. 389,

390 (1971). “Substantial evidence is more than a scintilla and is such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155, 1158 (11th Cir. 2004) (per curiam). Where the Commissioner’s decision is supported by

substantial evidence, the district court will affirm, even if the reviewer would have reached a contrary result as finder of fact, and even if the reviewer finds that the evidence preponderates against the Commissioner’s decision. Edwards v. Sullivan, 937 F.2d 580, 584 n.3 (11th Cir. 1991); Barnes v.

Sullivan, 932 F.2d 1356, 1358 (11th Cir. 1991) (per curiam). The district court must view the evidence as a whole, taking into account evidence favorable as well as unfavorable to the decision. Foote v. Chater, 67 F.3d 1553, 1560 (11th Cir. 1995) (per curiam); accord Lowery v. Sullivan, 979 F.2d

835, 837 (11th Cir. 1992) (stating the court must scrutinize the entire record to determine the reasonableness of the Commissioner’s factual findings). II. Discussion A. Issues on Appeal

Plaintiff raises two arguments on appeal: (1) that the ALJ erred in finding that Plaintiff was overpaid DIB in the amount of $65,720.50 for the period of November 30, 2011 through August 31, 2015; and (2) that the ALJ erred in finding that Plaintiff was at fault for causing the alleged

overpayment. (Doc. 29.) Defendant responds that substantial evidence supports the ALJ’s finding that Plaintiff was overpaid DIB in the amount of $65,720.50 for the period of November 30, 2011 to August 31, 2015, because his disability and

entitlement to DIB ended in November of 2011 when his monthly earnings reached $1,040.39. (Doc. 32 at 1-2.) Defendant explains that the amount of Plaintiff’s earnings after his entitlement to DIB ended is irrelevant. (Id. at 9 (“Even if Plaintiff had no earnings after November 2011, that would not

change the fact that he was no longer entitled to DIB.”).) Defendant also points out that “Plaintiff’s argument that his earnings from 2011 through 2015 were below SGA [i.e., substantial gainful activity] levels incorrectly relies on the monthly average of his yearly earnings given his work history.”

(Id. (citing 20 C.F.R. §§ 404.1592a(a)(3)(i), 404.1574a(d)).) Regarding the second issue on appeal, Defendant responds that substantial evidence supports the ALJ’s finding that Plaintiff was at fault for causing the overpayment and was, therefore, not entitled to a waiver of recovery for the overpayment. (Id. at 1.) Defendant explains:

The record provides ample evidence that Plaintiff knew that he should have reported his earnings to [the] SSA [i.e., the Social Security Administration] and that he accepted DIB payments that he knew, or could have been expected to know, were incorrect. Several SSA communications between February and October [of] 2011 informed Plaintiff of an earlier overpayment he received for failing to report the substantial work he performed starting in 2008. These communications informed Plaintiff that his work activity did and could continue to affect his entitlement to DIB. Despite these notices, Plaintiff failed to inform [the] SSA of his substantial work activity in November [of] 2011. Furthermore, despite his substantial earnings in November [of] 2011[,] Plaintiff continued to accept DIB from November [of] 2011 through August [of] 2015 that he knew or could be expected to know were incorrect.

(Id. at 1-2.) B. Administrative Proceedings and Relevant Record Evidence

Plaintiff was found disabled as of July 22, 2000 and entitled to DIB starting March of 2001. (See, e.g., Tr. 15, 17, 19-21.) On May 10, 2010, the SSA conducted a continuing disability review and determined that Plaintiff’s entitlement to DIB ended in June of 2008, which was the first month of SGA after his trial work period (“TWP”).2 (Tr. 19-20.) Plaintiff’s extended period

2 The TWP allows a claimant receiving DIB to test his ability to work while receiving benefits. See 42 U.S.C. § 422(c)(2); 20 C.F.R. § 404.1592(a). Generally, the TWP spans the first nine months that the claimant engages in work even if the work is not SGA and the months are not consecutive. See 42 U.S.C. § 422(c)(4); 20 C.F.R. § 404.1592(a)-(b). A claimant may work receiving SGA levels of earnings during the TWP and still receive DIB. See 20 C.F.R. § 404.316(d) (“Earnings during of eligibility (“EPE”)3 began in June of 2008. (Tr. 20.) The SSA determined that, as of July 2, 2010, Plaintiff had an overpayment balance in the amount

of $16,638.00. (Tr. 25.) On February 3, 2011, the SSA issued a revised determination that Plaintiff was no longer entitled to DIB as of September of 2008. (Tr. 27-29, 31.) The letter explained that Plaintiff’s TWP ended in May of 2008, but

because the SSA pays “benefits for the month disability ends and the following 2 months no matter how much is earned,” Plaintiff would be paid benefits through August of 2008. (Tr. 31.) The letter advised that Plaintiff’s EPE began in June of 2008; the EPE would last thirty-six months until June

of 2011; during the EPE, the SSA would restart payments for any month(s)

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