Minor v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedMarch 17, 2025
Docket6:24-cv-00058
StatusUnknown

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

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA JASPER DIVISION

TERRI MINOR, } } Plaintiff, } } v. } Case No. 6:24-cv-00058-MHH } LELAND DUDEK, ACTING } COMMISSIONER OF SOCIAL } SECURITY, 1 } } Defendant. }

MEMORANDUM OPINION Terri Denise Minor has asked the Court to review a final adverse decision of the Commissioner of Social Security. The Commissioner denied Ms. Minor’s claims for a period of disability and disability insurance benefits based on the Administrative Law Judge’s finding that Ms. Minor was not disabled. Ms. Minor challenges the finding. This opinion resolves her appeal.

1 On February 17, 2025, Leland Dudek became the Acting Commissioner of the Social Security Administration. Pursuant to Federal Rule of Civil Procedure 25(d), the Court substitutes Commissioner Dudek as the defendant in this action. See Fed. R. Civ. P. 25(d) (Although the public officer’s “successor is automatically substituted as a party” when the predecessor no longer holds office, the “court may order substitution at any time. . . .”). ADMINISTRATIVE PROCEEDINGS To succeed in her administrative proceedings, Ms. Minor had to prove she

was disabled. Gaskin v. Comm’r of Soc. Sec., 533 Fed. Appx. 929, 930 (11th Cir. 2013). “A claimant is disabled if [s]he is unable to engage in substantial gainful activity by reason of a medically-determinable impairment that can be expected to

result in death or which has lasted or can be expected to last for a continuous period of at least 12 months.” Gaskin, 533 Fed. Appx. at 930 (citing 42 U.S.C. § 423(d)(1)(A)).2 To determine whether a claimant has proven that she is disabled, an ALJ

follows a five-step sequential evaluation process. The ALJ considers: (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.

2 Title II of the Social Security Act governs applications for benefits under the Social Security Administration’s disability insurance program. Title XVI of the Act governs applications for Supplemental Security Income or SSI. “For all individuals applying for disability benefits under title II, and for adults applying under title XVI, the definition of disability is the same.” See https://www.ssa.gov/disability/professionals/bluebook/general-info.htm (lasted visited Jan. 27, 2025). Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011). “The claimant has the burden of proof with respect to the first four steps.” Wright v.

Comm’r of Soc. Sec., 327 Fed. Appx. 135, 136-37 (11th Cir. 2009). “Under the fifth step, the burden shifts to the Commissioner to show that the claimant can perform other jobs that exist in the national economy.” Wright, 327 Fed. Appx. at 137.

Ms. Minor applied for a period of disability and disability insurance benefits on April 14, 2021. (Doc. 7-4, pp. 93-97). Ms. Minor alleged that her disability began on April 11, 2021. (Doc. 7-4, p. 94). The Social Security Commissioner initially denied Ms. Minor’s claims, and Ms. Minor requested a hearing before an

Administrative Law Judge. (Doc. 7-3, pp. 129-147; Doc. 7-4, pp. 16-17). Ms. Minor and her attorney attended a telephone hearing with an ALJ on April 25, 2023. (Doc. 7-3, pp. 110-128). A vocational expert testified at the hearing. (Doc. 7-3, pp. 123-

128). The ALJ issued an unfavorable decision on May 31, 2023. (Doc. 7-3, pp. 11- 23). On November 22, 2023, the Appeals Council declined Ms. Minor’s request for review, (Doc. 7-3, p. 1), making the Commissioner’s decision final and thus a proper

candidate for this Court’s judicial review. See 42 U.S.C. § 405(g). EVIDENCE IN THE ADMINISTRATIVE RECORD Ms. Minor’s Medical Records

To support her application, Ms. Minor relied on medical records relating to the treatment and diagnoses of type 2 diabetes, diabetic autonomic neuropathy, urge fecal incontinence, chronic diarrhea, gastroparesis, cataracts, a detached retina in her

left eye, and obesity.3 The Court has reviewed Ms. Minor’s complete medical history and summarizes the following medical records because they are most relevant to the Court’s decision in this appeal. On January 6, 2020, Ms. Minor saw Dr. Steve Johnson and reported that she

worked at Wal-Mart, had not been “evaluated in three years,” and wanted to “establish [a] new primary care physician.” (Doc. 7-6, p. 79). Ms. Minor’s medical history included type 2 diabetes, obesity, hyperandrogenism, chronic left lower

quadrant abdominal wall abscess, and depression. (Doc. 7-6, p. 79).4 Ms. Minor

3 “Autonomic neuropathy occurs when there is damage to the nerves that control automatic body functions.” Autonomic neuropathy can affect digestion and cause “loss of appetite, diarrhea, constipation, abdominal bloating, nausea, vomiting, difficulty swallowing and heartburn.” See https://www.mayoclinic.org/diseases-conditions/autonomic-neuropathy/symptoms-causes/syc- 20369829 (last visited Jan. 27, 2025).

“Gastroparesis is a condition in which the muscles in the stomach don’t move food as they should for it to be digested. . . . . Gastroparesis affects digestion. It can cause nausea, vomiting and belly pain. It also can cause problems with blood sugar levels and nutrition. There’s no cure for gastroparesis. But medicines and changes to diet can give some relief.” See https://www.mayoclinic.org/diseases-conditions/gastroparesis/symptoms-causes/syc-20355787 (last visited Jan. 27, 2025).

4 “Hyperandrogenism is defined as the condition characterized by clinical signs of androgen excess, such as acne, hirsutism, or androgenic alopecia, or by the presence of elevated levels of weighed 210 pounds. (Doc. 7-6, p. 79). Dr. Johnson noted that Ms. Minor had poor control of her diabetes. (Doc. 7-6, p. 79). Dr. Johnson indicated that Ms. Minor had

had “extensive left lower quadrant abdominal wall debridement” surgery three years earlier and that the abdominal wall abscess had “never completely closed in.” (Doc. 7-6, p. 79). Dr. Johnson prescribed an antibiotic for the abdominal wall abscess,

referred Ms. Minor to the wound center, and indicated that Ms. Minor needed better control of her diabetes. (Doc. 7-6, p. 79). On January 20, 2020, Dr. Johnson noted that Ms. Minor had poor control of her diabetes because she “simply [did] not take her insulin.” (Doc. 7-6, p. 89).

At an April 13, 2020 visit, Ms. Minor weighed 217 pounds. (Doc. 7-5, pp. 81-82). Her medications included Lasix, Lexapro, BuSpar, Lotrel, Novolin, and metformin. (Doc. 7-5, p. 81).5 Ms. Minor denied having abdominal pain, diarrhea,

circulating androgens in the body.” See https://www.sciencedirect.com/topics/neuroscience/hyperandrogenism (last visited Jan. 29, 2025). 5 Lasix is a diuretic used to reduce fluid retention caused by congestive heart failure, liver disease, and kidney disease.

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