Parten v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedSeptember 30, 2025
Docket2:24-cv-00381
StatusUnknown

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

Opinion

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

JENNIFER PARTEN, ] ] Plaintiff, ] ] v. ] Case No.: 2:24-cv-00381-ACA ] COMMISSIONER, SOCIAL ] SECURITY ADMINISTRATION, ] ] Defendant. ] ]

MEMORANDUM OPINION Plaintiff Jennifer Parten appeals the Social Security Commissioner’s denial of her claim for supplemental security income. (Doc. 1). After review of the administrative record and the parties’ briefs, the court WILL AFFIRM the Commissioner’s decision. I. PROCEDURAL HISTORY Ms. Parten applied for supplemental security income in March 2011, alleging a disability beginning June 1, 2008. (Doc. 5-6 at 2). She later amended the onset date to March 18, 2011. (Doc. 5-3 at 62). The Commissioner denied Ms. Parten’s initial claim, and Ms. Parten requested a hearing before an administrative law judge (“ALJ”). (Doc. 5-5 at 2–4, 10). After the hearing (doc. 5-3 at 59–92), the ALJ issued an unfavorable decision (id. at 44–53). The Appeals Council denied Ms. Parten’s request for review, so she appealed. (Doc 5-3 at 23; doc. 5-11 at 31–32). The district court reversed and remanded the decision because substantial evidence did not

support the ALJ’s rejection of certain medical opinions, and the ALJ had not addressed Ms. Parten’s poverty status when considering her compliance with her medication regimen. (Doc. 5-11 at 45–51).

On remand, the ALJ held a second hearing. (Doc. 5-10 at 36–98). The ALJ again issued an unfavorable opinion, and the Appeals Council denied Ms. Parten’s request for review. (Id. at 2–4, 17–30). On appeal, the district court reversed and remanded because substantial evidence did not support the ALJ’s decision to

discount Ms. Parten’s subjective testimony of her symptoms. (Doc. 5-17 at 36–65). Specifically, the ALJ failed to “(1) consider the claimant’s inability to pay for medication; (2) sufficiently consider the side effects of the claimant’s medication;

(3) find with sufficient evidence that the claimant’s activities contradict her testimony of her symptoms; and (4) sufficiently consider the claimant’s difficulties with her activities.” (Id. at 64). On remand for a second time, Ms. Parten received a third hearing. (Doc. 5-16

at 46–111). The ALJ again found that she was not disabled and denied the claim, and the Appeals Council declined to review the decision. (See doc. 5-16 at 2, 17– 37). Accordingly, the Commissioner’s decision is final and ripe for the court’s

judicial review. See 42 U.S.C. § 405(g). II. STANDARD OF REVIEW The court’s role in reviewing claims under the Social Security Act is narrow.

The court “must determine whether the Commissioner’s decision is supported by substantial evidence and based on proper legal standards.” Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011) (quotation marks omitted). “Under

the substantial evidence standard, this court will affirm the ALJ’s decision if there exists such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Henry v. Comm’r of Soc. Sec., 802 F.3d 1264, 1267 (11th Cir. 2015) (quotation marks omitted). The court “may not decide the facts anew, reweigh

the evidence, or substitute [its] judgment for that of the [ALJ].” Winschel, 631 F.3d at 1178 (quotation marks omitted). The court must affirm “[e]ven if the evidence preponderates against the Commissioner’s findings.” Crawford v. Comm’r of Soc.

Sec., 363 F.3d 1155, 1158–59 (11th Cir. 2004) (quotation marks omitted). Despite the deferential standard of review, the court “must scrutinize the record as a whole to determine if the decision reached is reasonable and supported by substantial evidence.” Henry, 802 F.3d at 1267. The court must reverse the

Commissioner’s decision if the ALJ does not apply the correct legal standards or “provide the reviewing court with sufficient reasoning for determining that the proper legal analysis has been conducted.” Cornelius v. Sullivan, 936 F.2d 1143,

1145–46 (11th Cir. 1991). To determine whether an individual 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.

Winschel, 631 F.3d at 1178. III. EVIDENCE AND ALJ’S DECISION Ms. Parten’s case spans more than ten years and three ALJ hearings. Because of the voluminous record, the court outlines only the evidence relevant to Ms. Parten’s arguments on appeal. The court then summarizes the most recent ALJ’s decision. 1. Evidence Before the 2023 ALJ In 2008, Ms. Parten saw Dr. Sterling Taylor for psychotherapy. (Doc. 5-8 at 153). After six weekly sessions, Dr. Taylor diagnosed Ms. Parten with bipolar I disorder, obsessive-compulsive disorder, and panic disorder, noting that she suffered from panic attacks, dysphoria, depression, rages, suicidal ideations, hopelessness, a fear of death, and a “number of obsessions.” (Id. at 154–55). He opined that Ms. Parten was “totally and permanently disabled to work.” (Id. at 152). But no record of Ms. Parten’s six sessions accompanies Dr. Taylor’s report. (See id.).

Dr. Taylor referred Ms. Parten to Dr. Bruce Atkins, a psychiatrist, who treated Ms. Parten from 2008 until 2011. (Doc. 5-8 at 158–183). He diagnosed Ms. Parten with schizoaffective bipolar disorder, obsessive-compulsive disorder, panic

disorder, and sleep apnea. (Id. at 182–83). During that time, Ms. Parten attempted to commit suicide by overdosing on medication and was admitted to Northport Medical Center. (Doc. 5-8 at 5). Leading up to the event, Ms. Parten had not complied with her prescribed treatment. (Id. at 17).

When Ms. Parten applied for disability in 2011, her then-husband completed a function report on her behalf. (See doc. 5-7 at 14–21). He reported that she needed some reminders to bathe and take her medication. (Id. at 16, 19). She was anxious

to go to new places, forgot what she was doing, thought obsessively about death, did not drive, and could not be left alone for a long period of time. (Id. at 15, 17, 19– 20). However, she could prepare simple meals, get along with authority figures, sometimes follow written instructions, get along with others, go shopping, and

maintain her personal care. (Id. at 15–20). In June 2011, Dr. Hope Jackson reviewed Ms. Parten’s record and found that Ms. Parten had mild and moderate limitations in three of the four paragraph B criteria for the listed impairments in 20 C.F.R. pt. 404, subpart P, appendix 1 based on the function report and other evidence. (See doc. 5- 8 at 184–94).

In 2012, Ms. Parten visited the West Alabama Mental Health Center, where she reported suicidal thoughts, hallucinations, mania, panic, depression, and anxiety. (Doc. 5-9 at 3, 5–6). But Ms. Parten had normal speech, mood, impulse control,

memory, judgment, and productivity. (Id.).

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