Scott Macfarlane v. Commissioner of Social Security

CourtDistrict Court, S.D. Florida
DecidedApril 13, 2026
Docket0:25-cv-61135
StatusUnknown

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

Bluebook
Scott Macfarlane v. Commissioner of Social Security, (S.D. Fla. 2026).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 25-CV-61135-STRAUSS

SCOTT MACFARLANE,

Plaintiff, v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant. __________________________________/

ORDER ON MOTIONS FOR SUMMARY JUDGMENT THIS MATTER came before the Court upon Plaintiff’s Motion for Summary Judgment (“Plaintiff’s Motion”) [DE 7] and Defendant’s Motion for Summary Judgment (“Defendant’s Motion”) [DE 9]. The Court has reviewed both motions and all other pertinent portions of the record. For the reasons discussed herein, Plaintiff’s Motion [DE 7] will be DENIED and Defendant’s Motion [DE 9] will be GRANTED. I. BACKGROUND & PROCEDURAL HISTORY On July 26, 2021, Plaintiff applied for disability insurance benefits, alleging a disability onset date of March 29, 2020 (“Alleged Onset Date” or “AOD”). Tr. 28, 83, 92, 188-94. His claim was denied initially and upon reconsideration. See Tr. 28, 83-100. Thereafter, on August 24, 2023, Plaintiff appeared with counsel for a hearing before an Administrative Law Judge (“ALJ”), at which Plaintiff and a vocational expert testified. Tr. 44-78. On November 17, 2023, the ALJ issued a decision finding that Plaintiff was not disabled. Tr. 28-39. On November 26, 2024, the Appeals Council denied Plaintiff’s request for review, thereby leaving the ALJ’s decision as the final decision of the Commissioner. Tr. 12-14. Consequently, on June 6, 2025, Plaintiff commenced this action seeking review of the Commissioner’s decision. II. STANDARD OF REVIEW In reviewing claims brought under the Social Security Act, a court’s role is limited.

Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983). The Commissioner’s findings of fact must be affirmed if they are based upon “substantial evidence.” See 42 U.S.C. § 405(g); Richardson v. Perales, 402 U.S. 389, 401 (1971); Moore v. Barnhart, 405 F.3d 1208, 1211 (11th Cir. 2005). “Substantial evidence is . . . such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Moore, 405 F.3d at 1211 (citing Crawford v. Comm’r of Soc. Sec., 363 F.3d 1155, 1158 (11th Cir. 2004)). It “is something ‘more than a mere scintilla, but less than a preponderance.’” Dyer v. Barnhart, 395 F.3d 1206, 1210 (11th Cir. 2005) (citation omitted). “If the Commissioner’s decision is supported by substantial evidence, this Court must affirm, even if the proof preponderates against it.” Id. (quoting Phillips v. Barnhart, 357 F.3d 1232, 1240 n.8 (11th Cir. 2004)). Courts “may not decide the facts anew, reweigh the evidence,

or substitute [their] judgment for that of the [Commissioner].” Id. (quoting Phillips, 357 F.3d at 1240 n.8); Bloodsworth, 703 F.2d at 1239. In addition to determining whether the Commissioner’s factual findings are supported by substantial evidence, courts must determine whether the ALJ applied the correct legal standards. Wilson v. Barnhart, 284 F.3d 1219, 1221 (11th Cir. 2002). III. DISCUSSION A. THE SEQUENTIAL EVALUATION A “disability” is defined as an 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. § 1382c(a)(3)(A). To arrive at a disability determination, the ALJ must undertake the five-step sequential evaluation set forth in 20 C.F.R. § 404.1520. The first step requires the ALJ to determine whether the claimant is presently engaged in substantial gainful activity. 20 C.F.R. § 404.1520(b). If so, a finding of “no disability” is made.

If the claimant is not engaged in such work, then the ALJ must proceed to the second step and determine whether the claimant suffers from a “severe impairment.” An impairment is severe if it significantly limits the claimant’s physical or mental ability to perform basic work activities. 20 C.F.R. § 404.1520(c). If no severe impairment is found, then the ALJ will conclude that the claimant is not disabled; if a severe impairment is found, then the ALJ will proceed to the next step of the sequential evaluation. See 20 C.F.R. § 404.1520(c). The third step requires the ALJ to determine whether the claimant’s impairment meets or equals those listed in Appendix 1 of the Regulations. 20 C.F.R. § 404.1520(d). If so, the ALJ will find the claimant disabled without considering age, education, and work experience. 20 C.F.R. § 404.1520(d). If not, the inquiry will proceed to the next step.

Step four requires the ALJ to determine whether the claimant has the residual functional capacity (“RFC”) to perform past relevant work. 20 C.F.R. § 404.1520(e). The Regulations define RFC as “the most you can still do despite your limitations.” 20 C.F.R. § 404.1545(a)(1). The RFC determination takes into account “all of the relevant medical and other evidence,” including the claimant’s own testimony and the observations of others. 20 C.F.R. § 404.1545(a)(3). The ALJ must compare the claimant’s RFC with the physical and mental demands of the claimant’s past relevant work to determine whether the claimant is still capable of performing that kind of work. If so, the claimant is found not disabled. 20 C.F.R. § 404.1520(f). If the claimant establishes an inability to return to past relevant work (or does not have past relevant work), the inquiry turns to step five. “At step five the burden of going forward shifts to the [Commissioner] ‘to show the existence of other jobs in the national economy which, given the claimant’s impairments, the claimant can perform.’” Washington v. Comm’r of Soc. Sec., 906 F.3d

1353, 1359 (11th Cir. 2018) (quoting Hale v. Bowen, 831 F.2d 1007, 1011 (11th Cir. 1987)). If the Commissioner points to possible alternative employment, then the burden returns to the claimant to prove an inability to perform those jobs. Id.

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Scott Macfarlane v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scott-macfarlane-v-commissioner-of-social-security-flsd-2026.