Murphy v. Commissioner of Social Security

CourtDistrict Court, M.D. Florida
DecidedMarch 1, 2022
Docket8:20-cv-01849
StatusUnknown

This text of Murphy v. Commissioner of Social Security (Murphy 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
Murphy v. Commissioner of Social Security, (M.D. Fla. 2022).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA TAMPA DIVISION

CHRISTEN LEIGH MURPHY,

Plaintiff,

v. Case No. 8:20-cv-1849-T-SPF

KILOLO KIJAKAZI,1 Acting Commissioner of the Social Security Administration,

Defendant. /

ORDER

Plaintiff seeks judicial review of the denial of her claim for Supplemental Security Income (“SSI”). As the Administrative Law Judge’s (“ALJ”) decision was not based on substantial evidence and failed to employ proper legal standards, the Commissioner’s decision is reversed. I. Procedural Background

Plaintiff filed an application for SSI (Tr. 725-30). The Commissioner denied Plaintiff’s claim both initially and upon reconsideration (Tr. 587, 606). Plaintiff then requested an administrative hearing (Tr. 623-25). Per Plaintiff’s request, the ALJ held a hearing at which Plaintiff appeared and testified (Tr. 38-63). Following the hearing, the ALJ issued an unfavorable decision finding Plaintiff not disabled and accordingly denied Plaintiff’s claim for benefits (Tr. 21-29). Subsequently, Plaintiff requested review from the Appeals Council,

1 Kilolo Kijakazi became the Acting Commissioner of Social Security on July 9, 2021 and is substituted as Defendant in this suit pursuant to Rule 25(d) of the Federal Rules of Civil Procedure. which the Appeals Council denied (Tr. 1-3). Plaintiff then timely filed a complaint with this Court (Doc. 1). The case is now ripe for review under 42 U.S.C. §§ 405(g), 1383(c)(3). II. Factual Background and the ALJ’s Decision Plaintiff, who was born in 1980, claimed disability beginning January 15, 2016 (Tr.

21).2 Plaintiff has a high school education and some college credits (Tr. 41). She has no past relevant work experience (Tr. 42). Plaintiff alleged disability due to bipolar disorder, fibromyalgia, arthritis, lupus, common variable immune deficiency (CVID), migraines, allergies, asthma, chronic fatigue syndrome (CFS), and gastritis (Tr. 744). In rendering the administrative decision, the ALJ concluded that Plaintiff had not engaged in substantial gainful activity since December 6, 2016, her application date (Tr. 23). After conducting a hearing and reviewing the evidence of record, the ALJ determined Plaintiff had the following severe impairments: fibromyalgia, connective tissue disease, degenerative disc disease (DDD), migraines, asthma, obesity, anxiety, and depression (Id.).

Notwithstanding the noted impairments, the ALJ determined Plaintiff did not have an impairment or combination of impairments that met or medically equaled one of the listed impairments in 20 C.F.R. Part 404, Subpart P, Appendix 1 (Id.). The ALJ then concluded that Plaintiff retained a residual functional capacity (“RFC”) to perform light work with these limitations: [T]he claimant can lift 20 pounds occasionally and 10 pounds frequently; stand/walk 6 hours per day; and sit 6 hours per day. The claimant should never climb ladders, rope[s], or scaffold[s]; and can occasionally climb ramp[s]/stairs, balance, stoop, kneel, crouch, and crawl. The claimant can frequently reach, handle, finger, and feel; but must avoid wetness and humidity, loud noise, vibration, pulmonary irritants, temperature extremes, hazardous machinery and

2 Although Plaintiff claims an onset date of January 15, 2016, the relevant period for her SSI claim is the month she filed her application (December 2016) through the date of the ALJ’s decision (July 25, 2019). See 20 C.F.R. §§ 416.330, 416.335. heights. In addition, the claimant can perform simple[,] routine[,] repetitive tasks such as unskilled work with an SVP of one or 2 and a GED reasoning level up to 3. The claimant can handle occasional and routine changes in work settings or duties; but cannot perform fast-paced production or quota-driven work, such as assembly lines. However, the claimant can have occasional interaction with the public, coworkers, supervisors; and can maintain attention and concentration for 2 hours at a time, but then requires a 10 minute break.

(Tr. 25). In formulating Plaintiff’s RFC, the ALJ considered Plaintiff’s subjective complaints and determined that, although the evidence established the presence of underlying impairments that reasonably could be expected to produce the symptoms alleged, Plaintiff’s statements as to the intensity, persistence, and limiting effects of her symptoms were not entirely consistent with the medical evidence and other evidence (Tr. 26). The ALJ considered Plaintiff’s noted impairments and the assessment of a vocational expert (“VE”). Given Plaintiff’s background and RFC, the VE testified that Plaintiff could perform jobs existing in significant numbers in the national economy, such as marker/pricer and private sector mail clerk (Tr. 28). Accordingly, based on Plaintiff’s age, education, RFC, and the testimony of the VE, the ALJ found Plaintiff not disabled (Tr. 29). III. Legal Standard To be entitled to benefits, a claimant must be disabled, meaning he or she must be unable to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death, or 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” is an impairment 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). The Social Security Administration, to regularize the adjudicative process, promulgated the detailed regulations currently in effect. These regulations establish a “sequential evaluation process” to determine whether a claimant is disabled. 20 C.F.R. § 416.920. If an individual is found disabled at any point in the sequential review, further

inquiry is unnecessary. 20 C.F.R. § 416.920(a). Under this process, the ALJ must determine, in sequence, the following: whether the claimant is currently engaged in substantial gainful activity; whether the claimant has a severe impairment, i.e., one that significantly limits the ability to perform work-related functions; whether the severe impairment meets or equals the medical criteria of 20 C.F.R. Part 404 Subpart P, Appendix 1; and whether the claimant can perform his or her past relevant work. If the claimant cannot perform the tasks required of his or her prior work, step five of the evaluation requires the ALJ to decide if the claimant can do other work in the national economy in view of his or her age, education, and work experience. 20 C.F.R. § 416.920(a). A claimant is entitled to benefits only if unable to perform other work. Bowen v. Yuckert, 482 U.S. 137, 140-42 (1987); 20 C.F.R.

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