Murdock v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedMarch 20, 2025
Docket4:24-cv-00015
StatusUnknown

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

Opinion

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

CHRISTOPHER SCOTT } MURDOCK }

} Plaintiff, }

v. } }

} CASE NO.: 4:24-cv-00015-MHH LELAND DUDEK, ACTING } COMMISSIONER OF SOCIAL } SECURITY, 1 } } Defendant.

MEMORANDUM OPINION

Christopher Murdock has asked the Court to review a final adverse decision of the Commissioner of Social Security. The Commissioner denied Mr. Murdock’s claims for a period of disability, disability insurance benefits, and supplemental security income based on an Administrative Law Judge’s finding that Mr. Murdock was not disabled. Mr. Murdoch argues that, in denying his request for benefits, the Administrative Law Judge—the ALJ—improperly evaluated his (Mr. Murdock’s)

1 On February 17, 2025, Leland Dudek became the Acting Commissioner of the Social Security Administration. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, 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. . . .”). subjective complaints of pain under the Eleventh Circuit pain standard. For the reasons discussed below, the Court affirms the Commissioner’s decision.

ADMINISTRATIVE PROCEEDINGS To succeed in his administrative proceedings, Mr. Murdock had to prove that he was disabled. Gaskin v. Comm’r of Soc. Sec., 533 Fed. Appx. 929, 930 (11th Cir.

2013). “A claimant is disabled if 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 he 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 his 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 Nov. 19, 2024). Winschel v. Comm’r of Soc. Sec. Admin, 631 F.3d 116, 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.

On November 9, 2020, Mr. Murdock applied for a period of disability, disability insurance benefits, and supplemental security income. (Doc. 4-6, pp. 2- 16). Mr. Murdoch alleged that his disability began on November 30, 2019. (Doc. 4-6, p. 2). The Commissioner denied Mr. Murdock’s claims on July 1, 2021, and

Mr. Murdock requested a hearing before an ALJ. (Doc. 4-5, p. 8). Mr. Murdock and his attorney attended a telephone hearing before the ALJ on January 18, 2023. (Doc. 4-3, pp. 20, 45-63).3 A vocational expert testified at the hearing. (Doc. 4-3,

pp. 58-62). The ALJ issued an unfavorable decision on May 17, 2023. (Doc. 4-3, pp. 20- 37). On November 6, 2023, the Appeals Council declined Mr. Murdock’s request for review, (Doc. 4-4, p. 17), making the Commissioner’s decision a proper

candidate for this Court’s judicial review. See 42 U.S.C. § 405(g).

3 Mr. Murdock and his attorney appeared in person at the Social Security office, and the ALJ participated in the hearing via telephone conference. (Doc. 4-3, pp. 47-48). EVIDENCE IN THE ADMINISTRATIVE RECORD4 Mr. Murdock’s Medical Records

To support his application, Mr. Murdock relied on medical records relating to the diagnosis and treatment of right shoulder rotator cuff repair, degenerative joint disease of the bilateral shoulders, status post total left knee arthroplasty with

revision, degenerative joint disease of the right knee, bilateral osteoarthritis of the knees, obesity, obstructive sleep apnea, diabetes mellitus, polycythemia, peptic ulcer disease, acute kidney injury, COVID-19 infection, hypertension, and hyperlipidemia.5 The Court has reviewed Mr. Murdock’s complete medical history

and summarizes the following medical records because they are most relevant to Mr. Murdock’s arguments in this appeal. On May 7, 2015, Mr. Murdock saw orthopedic surgeon Dr. William Haller

for treatment for degenerative joint disease. (Doc 4-8, pp. 16-19). Dr. Haller noted that Mr. Murdock previously had “ACL reconstruction” surgery “after trauma to the [left] knee” and “slowly developed osteoarthritic changes.” (Doc. 4-8, p. 16). Mr. Murdock had joint swelling, pain, tenderness, and normal alignment, strength, and

4 In his brief, Mr. Murdock adopted the ALJ’s description of his age, education, and work experience and the ALJ’s summary of his (Mr. Murdock’s) testimony. (Doc. 8, p. 4).

5 Polycythemia is “type of blood cancer” that “causes your bone marrow to make too many red blood cells . . . [P]roper medical care can help ease signs, symptoms, and complications of this disease.” See https://www.mayoclinic.org/diseases-conditions/polycythemia-vera/symptoms- causes/syc-20355850 (last visited Nov. 19, 2024). range of motion in his left knee; intact sensation; normal muscle tone in his legs; and a normal gait. (Doc. 4-8, pp. 16-17). Dr. Haller indicated that he had treated Mr.

Murdock’s left knee problems with a “home exercise program, medications[,] and injections without resolution.” (Doc. 4-8, pp. 16, 18). Dr. Haller recommended a left total knee arthroplasty and physical therapy. (Doc. 4-8, p. 18).

On May 12, 2015, Dr. Haller began Mr. Murdock’s total left knee replacement surgery but had to stop when Mr. Murdock experienced cardiac arrest. (Doc. 4-8, pp. 22-23, 26-27). A post-operative EKG revealed normal sinus rhythm with no acute changes. (Doc. 4-8, p. 24). Mr. Murdock’s post-operative diagnoses included

degenerative joint disease in his left knee, cardiac arrest, and acute post-operative pain. (Doc. 4-8, p. 26). Dr. Haller noted that Mr. Murdock’s cardiac arrest was most likely related to hypertension medication prescribed by his primary care doctor.

(Doc. 4-8, p. 25). Mr. Murdock received an adductor canal block for his post- operative knee pain. (Doc. 4-8, p. 28).6 On May 19, 2015, Dr. Haller completed Mr. Murdock’s left knee replacement surgery with no complications. (Doc. 4-8, pp. 13-15). Mr.

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