Raughton v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedSeptember 21, 2021
Docket4:20-cv-00486
StatusUnknown

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

Opinion

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ALABAMA MIDDLE DIVISION TIMOTHY RAUGHTON ) ) Plaintiff, ) ) v. ) Case No. 4:20-cv-00486-SGC ) SOCIAL SECURITY ) ADMINISTRATION, Commissioner, ) ) Defendant. )

MEMORANDUM OPINION1 The plaintiff, Timothy Raughton, appeals from the decision of the Commissioner of the Social Security Administration (the “Commissioner”) holding he was not disabled within the meaning of the Social Security Act prior to November 18, 2018, but became disabled on that date and continued to be disabled through the date of the Commissioner’s decision. (Doc. 1).2 Raughton timely pursued and exhausted his administrative remedies, and the Commissioner’s decision is ripe for review pursuant to 42 U.S.C §§ 405(g) and 1383(c)(3). For the reasons discussed below, the Commissioner’s decision is due to be affirmed.

1 The parties have consented to the exercise of dispositive jurisdiction by a magistrate judge pursuant to 28 U.S.C. § 636(c). (Doc. 10).

2 Citations to the record refer to the document and page numbers assigned by the court’s CM/ECF electronic filing system and appear in the following format: (Doc. __ at __). Citations to the transcript use page numbers assigned by the Commissioner to the record and appear as follows: (Tr. at __). I. PROCEDURAL HISTORY Raughton graduated from high school with a special education certificate.

(Tr. at 36, 217). He has previously been employed as a garbage truck driver. (Id. at 52, 217-218, 246-47). In his application for a period of disability and disability insurance benefits (“DIB”), Raughton alleged he became disabled on July 11, 2016,

as a result of hernias, diabetes, obesity, back pain, and fluid collection on his stomach. (Id. at 58, 186-89, 216). After his claims were denied, Raughton requested a hearing before an administrative law judge (“ALJ”). (Id. at 83-84). On April 18, 2019, the ALJ held a video hearing at which David Head, an impartial vocational

expert, also appeared and testified. (Id. at 33, 51-54). Following the hearing, the ALJ held Raughton was not disabled prior to November 18, 2018, but became disabled on that date and continued to be disabled through the date of the ALJ’s

decision. (Id. at 17). Raughton was fifty years old when the ALJ issued his decision. (Id. at 13, 37, 186). After the Appeals Council declined to review the ALJ’s decision (id. at 1-6), that decision became the final decision of the Commissioner, see Frye v. Massanari, 209 F. Supp. 2d 1246, 1251 N.D. Ala. 2001 (citing Falge v. Apfel, 150

F.3d 1320, 1322 (11th Cir. 1998)). Thereafter, Raughton initiated this action. (Doc. 1). II. STATUTORY AND REGULATORY FRAMEWORK To establish eligibility for disability benefits, a claimant must show “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 a continuous period of not less than

twelve months.” 42 U.S.C. §§ 416(i)(1)(A), 423(d)(1)(A); see also id. at § 1382c(a)(3)(A); 20 C.F.R. §§ 404.1505(a), 416.905(a). Furthermore, a DIB claimant must show he was disabled between his alleged initial onset date and his date last insured. Mason v. Comm’r of Soc. Sec., 430 F. App’x 830, 831 (11th Cir.

2011) (citing Moore v. Barnhart, 405 F.3d 1209, 1211 (11th Cir. 2005); Demandre v. Califano, 591 F.2d 1088, 1090 (5th Cir. 1979)). The Social Security Administration employs a five-step sequential analysis to determine an individual’s

eligibility for disability benefits. 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4). First, the Commissioner must determine whether the claimant is engaged in “substantial gainful activity.” Id. “Under the first step, the claimant has the burden to show that she is not currently engaged in substantial gainful activity.” Reynolds-

Buckley v. Comm’r of Soc. Sec., 457 F. App’x 862, 863 (11th Cir. 2012). If the claimant is engaged in substantial gainful activity, the Commissioner will determine the claimant is not disabled. At the first step, the ALJ determined Raughton has not engaged in substantial gainful activity since the alleged onset date, July 11, 2016. (Tr. at 19).

If a claimant is not engaged in substantial gainful activity, the Commissioner must next determine whether the claimant suffers from a severe physical or mental impairment, or combination of impairments, which has lasted or is expected to last

for a continuous period of at least twelve months. 20 C.F.R. § 416.920 (a)(4)(ii), (c). An impairment “must result from anatomical, physiological, or psychological abnormalities which can be shown by medically acceptable clinical and laboratory diagnostic techniques.” 20 C.F.R. § 416.921. Furthermore, it “must be established

by medical evidence consisting of signs, symptoms, and laboratory findings, not only by [the claimant’s] statement of symptoms.” Id.; see 42 U.S.C. § 423(d)(3). An impairment is severe if it “significantly limits [the claimant’s] physical or

mental ability to do basic work activities . . . .” 20 C.F.R. § 416.922(c). “[A]n impairment can be considered as not severe only if it is a slight abnormality which has such a minimal effect on the individual that it would not be expected to interfere with the individual’s ability to work, irrespective of age, education, or work

experience.” Brady v. Heckler, 724 F.2d 914, 920 (11th Cir. 1984); see 20 C.F.R. § 404.1521(a). A claimant may be found disabled based on a combination of impairments, even though none of his individual impairments alone is disabling. 20

C.F.R. § 416.920. The claimant bears the burden of providing medical evidence demonstrating an impairment and its severity. 20 C.F.R. § 416.912(a). If the claimant does not have a severe impairment or combination of impairments, the

Commissioner will determine the claimant is not disabled. 20 C.F.R. § 416.920(a)(4)(ii), (c). At the second step, the ALJ determined Raughton has the following severe impairments: obesity, degenerative disc disease, diabetes mellitus,

gastritis, diverticulosis, hepatic steatosis, hernias, and pancreatitis. (Tr. at 19).

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