Ramsey v. Commissioner of the Social Security Administration

CourtDistrict Court, D. South Carolina
DecidedMay 30, 2023
Docket4:22-cv-02337
StatusUnknown

This text of Ramsey v. Commissioner of the Social Security Administration (Ramsey v. Commissioner of the Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, D. South Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Ramsey v. Commissioner of the Social Security Administration, (D.S.C. 2023).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF SOUTH CAROLINA FLORENCE DIVISION MANDY RAMSEY, ) Civil Action No.: 4:22-cv-02337-TER ) Plaintiff, ) ) -vs- ) ) ORDER KILOLO KIJAKAZI, ) Acting Commissioner of Social Security, ) ) Defendant. ) ___________________________________ ) This is an action brought pursuant to Section 205(g) of the Social Security Act, as amended, 42 U.S.C. Section 405(g), to obtain judicial review of a “final decision” of the Commissioner of Social Security, denying Plaintiff’s claim for supplemental security income(SSI). The only issues before the Court are whether the findings of fact are supported by substantial evidence and whether proper legal standards have been applied. This action is proceeding before the undersigned pursuant to 28 U.S.C. § 636(c) and Fed. R. Civ. Proc. R. 73. I. RELEVANT BACKGROUND A. Procedural History Plaintiff filed an application for SSI in July 2018, with an amended alleged onset date of July 2, 2018. (Tr. 15). Her claims were denied initially and upon reconsideration. Thereafter, Plaintiff filed a request for a hearing. Plaintiff and a vocational expert (VE) testified at a hearing in September 2021. The Administrative Law Judge (ALJ) issued an unfavorable decision on October 29, 2021, finding that Plaintiff was not disabled within the meaning of the Act. (Tr. 15-28). Plaintiff filed a request for review of the ALJ’s decision, which the Appeals Council denied in June 2022, making the ALJ’s decision the Commissioner’s final decision. (Tr.1-3). Plaintiff filed an action in this court in July 2022. (ECF No. 1). B. Plaintiff’s Background Plaintiff was born in March 1980, and was thirty-eight years old when the application was filed. (Tr. 27). Plaintiff has no past work. Plaintiff initially alleges disability due to depression,

anxiety, scoliosis, kidney tumor, chronic headaches, short temper, difficulty being in crowds, unable to sit/stand for long periods, and liver lesions. (Tr. 52). C. The ALJ’s Decision In the decision of October 2021, the ALJ made the following findings of fact and conclusions of law (Tr. 15-28): 1. The claimant has not engaged in substantial gainful activity since July 2, 2018, the application date (20 CFR 416.971 et seq.). 2. The claimant has the following severe impairments: pelvic inflammatory disease, scoliosis, bipolar disorder, depression, anxiety, and posttraumatic stress disorder (PTSD) (20 CFR 416.920(c)). 3. The claimant does not have an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1 (20 CFR 416.920(d), 416.925 and 416.926). 4. After careful consideration of the entire record, I find that the claimant has the residual functional capacity to perform light work as defined in 20 CFR 416.967(b) except the claimant cannot climb ladders or be exposed to unprotected heights or dangerous moving machinery; she can perform simple, routine tasks; the jobs should not have fast paced or team dependent production requirements; she can tolerate occasional public contact and occasional changes in the workplace/work methods, and with these restrictions in place, she can attend and focus in two hour increments. 5. The claimant has no past relevant work (20 CFR 416.965). 6. The claimant was born on March 15, 1980 and was 38 years old, which is defined as a younger individual age 18-49, on the date the application was 2 filed (20 CFR 416.963). 7. The claimant has at least a high school education (20 CFR 416.964). 8. Transferability of job skills is not an issue because the claimant does not have past relevant work (20 CFR 416.968). 9. Considering the claimant’s age, education, work experience, and residual functional capacity, there are jobs that exist in significant numbers in the national economy that the claimant can perform (20 CFR 416.969 and 416.969a). 10. The claimant has not been under a disability, as defined in the Social Security Act, since July 2, 2018, the date the application was filed (20 CFR 416.920(g)). II. DISCUSSION Plaintiff argues the ALJ erred in evaluating the statement from NP Anumula.1 (ECF No. 14 at 13-18). Plaintiff argues the ALJ did not explain why the RFC had no limitations regarding coworkers and supervisors. (ECF No. 14 at 18-22). Plaintiff argues the RFC did not account for a limitation in instructions that was opined by consultants whose opinions were found persuasive by the ALJ. (ECF No. 14 at 22-25). Plaintiff argues Commissioner Berryhill lacked the authority under the FVRA to continue acting as Commissioner and could not have appropriately appointed Plaintiff’s ALJ. (ECF No. 14 at 25-30). The Commissioner argues that the ALJ’s decision is supported by substantial evidence. A. LEGAL FRAMEWORK 1. The Commissioner’s Determination–of–Disability Process

1 The conclusion sentence of this issue states that the ALJ “failed to properly evaluate the opinion of NP Anumula and Ramsey’s subjective complaints. Remand is warranted for further evaluation of NP Anumula’s opinion.” (ECF No. 14 at 18). Plaintiff never cites to the factors for a subjective symptom evaluation in SSR 16-3p. 3 The Act provides that disability benefits shall be available to those persons insured for benefits, who are not of retirement age, who properly apply, and who are under a “disability.” 42 U.S.C. § 423(a). Section 423(d)(1)(A) defines disability as: the inability 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 at least 12 consecutive months. 42 U.S.C. § 423(d)(1)(A). To facilitate a uniform and efficient processing of disability claims, regulations promulgated under the Act have reduced the statutory definition of disability to a series of five sequential questions. See, e.g., Heckler v. Campbell, 461 U.S. 458, 460 (1983) (discussing considerations and noting the “need for efficiency” in considering disability claims). An examiner must consider the following: (1) whether the claimant is engaged in substantial gainful activity (“SGA”); (2) whether

he has a severe impairment; (3) whether that impairment meets or equals an impairment included in the Listings;2 (4) whether such impairment prevents claimant from performing PRW;3 and (5)

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Bluebook (online)
Ramsey v. Commissioner of the Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/ramsey-v-commissioner-of-the-social-security-administration-scd-2023.