Poole v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedMarch 11, 2021
Docket4:19-cv-01754
StatusUnknown

This text of Poole v. Social Security Administration, Commissioner (Poole 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
Poole v. Social Security Administration, Commissioner, (N.D. Ala. 2021).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA MIDDLE DIVISION CHRISTA POOLE, ) ) Plaintiff, ) ) v. ) Case No.: 4:19-cv-1754-LCB ) SOCIAL SECURITY ) ADMINISTRATION, ) COMMISSIONER, )

Defendant.

MEMORANDUM OPINION

On October 27, 2019, the Plaintiff, Christa Poole, filed a complaint seeking judicial review of an adverse decision of the Commissioner of the Social Security Administration (“the Commissioner”) pursuant to 42 U.S.C. § 405(g). The Commissioner filed an answer on March 30, 2020. Poole filed a brief in support of her position on May 27, 2020, and the Commissioner filed a response on July 1, 2020. Poole did not file a reply brief. Accordingly, the issue is now fully briefed and is ripe for review. For the reasons that follow, the Commissioner’s final decision is affirmed. I. Background Poole protectively filed an application for supplemental security income (“SSI”) on August 16, 2016, alleging disability beginning May 1, 2015. After the claim was denied on December 9, 2016, Poole requested a hearing before an Administrative Law Judge (“ALJ”). That hearing was held on September 11,

2018. Poole was represented by counsel and testified at the hearing, as did a vocational expert (“VE”). The ALJ subsequently issued an unfavorable decision. Poole then requested review of the ALJ’s decision by the Appeals Council, but that

request was denied on September 6, 2019. This lawsuit followed. II. The ALJ’s decision After the hearing, the ALJ issued a written opinion explaining his decision. (R. at 15-26). In issuing his decision, the ALJ followed the five-step evaluation

process set out by the Social Security Administration. 20 CFR 416.920(a). The steps are followed in order and, if it is determined that the claimant is or is not disabled at a particular step of the evaluation process, the ALJ will not proceed to

the next step. The first step requires the ALJ to determine whether the claimant is engaging in substantial gainful activity, which is defined as work involving significant physical or mental activities usually done for pay or profit. If a claimant is

engaged in substantial gainful activity, she is not disabled, and the inquiry stops. Otherwise, the ALJ will proceed to step two. In the present case, the ALJ found that Poole had not engaged in substantial gainful activity since August 16, 2016.

(R. at 17). Accordingly, the ALJ moved on to the second step of the evaluation. At step two, an ALJ is to determine whether the claimant has a medically determinable impairment that is “severe” or a combination of impairments that is

“severe.” 20 CFR 416.920(c). An impairment is severe if it “significantly limits [a claimant’s] physical or mental ability to do basic work activities….” Id. If a claimant does not have a severe impairment, she is not disabled, and the inquiry

ends. If she does have a severe impairment, the ALJ will proceed to the third step. In the present case, the ALJ found that Poole had the following severe impairments: obesity, diabetes mellitus with neuropathy, sleep-related breathing disorders, depression, and anxiety disorder. (R. at 17). The ALJ found that

Poole’s hypertension and hyperlipidemia were not severe. At the third step, an ALJ determines whether the claimant’s impairments or combination thereof are of a severity to meet or medically equal the criteria of an

impairment listed in 20 CFR Part 404, Subpart P, Appendix I. If the claimant’s impairment or impairments meet or equal a listed impairment, then the claimant is disabled, and the evaluation ends. Else, the ALJ proceeds to the next step. In this case, the ALJ found that Poole’s impairments did not meet or equal any of the

listed criteria and, therefore, proceeded to step four. Step four of the evaluation requires an ALJ to determine the claimant’s residual functional capacity (“RFC”), and whether she has the RFC to perform the

requirements of any past relevant work. 20 CFR 416.920(f). The term “past relevant work” means work performed within the last 15 years prior to the alleged date of onset. If a claimant has the RFC to perform past relevant work, she is not

disabled, and the evaluation stops. Otherwise, the evaluation proceeds to the final step. In Poole’s case, the ALJ found that she did not have the RFC to perform her past work as a certified nurse assistant or a cashier-stocker. (R. at 21). Therefore,

he proceeded to the final step in the evaluation process. At the final step, the ALJ considers whether the claimant is able to do any other work considering her RFC, age, education, and work experience. If a claimant is able to do other work, she is not disabled. If a claimant is unable to do

such work, then she is disabled. According to the ALJ, Poole had the RFC to perform sedentary work as defined in 20 CFR 416.967(a), with certain limitations. Id. After hearing testimony from a VE, the ALJ determined that there were jobs

existing in significant numbers in the national economy that Poole would be able to do given her RFC, age, education, and work experience. Specifically, the VE opined that Poole could perform the work of a wire wrapper, final assembler, and a stuffer. (R. 55). Therefore, the ALJ found, Poole was not disabled as defined by

the Social Security Administration. III. Standard of Review The Court must determine whether the Commissioner’s decision is

supported by substantial evidence and whether the correct legal standards were applied. Winschel v. Comm'r of Social Sec., 631 F.3d 1176, 1178 (11th Cir. 2011). “Substantial evidence is more than a scintilla and is such relevant evidence as a

reasonable person would accept as adequate to support a conclusion.” Id. (internal citation and quotation marks omitted). “This limited review precludes deciding the facts anew, making credibility determinations, or re-weighing the evidence.”

Moore v. Barnhart, 405 F.3d 1208, 1211 (11th Cir. 2005). Thus, while the Court must scrutinize the record as a whole, the Court must affirm if the decision is supported by substantial evidence, even if the evidence preponderates against the Commissioner’s findings. Henry v. Comm'r of Soc. Sec., 802 F.3d 1264 (11th Cir.

2015); Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983). IV. Poole’s arguments In her brief, Poole first contends that the ALJ did not properly evaluate her

obesity and its interplay with her other impairments. According to Poole, the medical evidence “seems to show a significant interplay between [her] problems with her diabetes and her problems with her weight….” (Doc. 13 at 15). Poole also claims that her sleep apnea and mental issues are worsened by her obesity. Id.

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Poole v. Social Security Administration, Commissioner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/poole-v-social-security-administration-commissioner-alnd-2021.