Sexton v. O'Malley (CONSENT)

CourtDistrict Court, M.D. Alabama
DecidedOctober 29, 2024
Docket2:24-cv-00006
StatusUnknown

This text of Sexton v. O'Malley (CONSENT) (Sexton v. O'Malley (CONSENT)) is published on Counsel Stack Legal Research, covering District Court, M.D. Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sexton v. O'Malley (CONSENT), (M.D. Ala. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF ALABAMA NORTHERN DIVISION

RHONDA SEXTON, ) ) Plaintiff, ) ) v. ) CASE NO. 2:24-CV-06-KFP ) MARTIN J. O’MALLEY, ) Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER Pursuant to 42 U.S.C. § 405(g), Plaintiff Rhonda Sexton filed a Complaint seeking review of the Social Security Administration’s decision denying her application for disability, disability insurance benefits, and supplemental security income. Doc. 1. The Court construes Plaintiff’s supporting brief (Doc. 10) as a motion for summary judgment and the Commissioner’s opposition brief (Doc. 11) as a motion for summary judgment. The parties have consented to the exercise of dispositive jurisdiction by a magistrate judge pursuant to 28 U.S.C. § 636(c). Docs. 6, 7. After scrutiny of the record and the motions submitted by the parties, the Court finds that Plaintiff’s motion for summary judgment is due to be DENIED, the Commissioner’s motion for summary judgment is due to be GRANTED, and the decision of the Commissioner is due to be AFFIRMED. I. STANDARD OF REVIEW This Court’s role in reviewing claims brought under the Social Security Act is a

narrow one. The scope is limited to determining whether substantial evidence in the record as a whole supports the Commissioner’s decision and whether the correct legal standards were applied. Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011). Substantial evidence is more than a scintilla but less than a preponderance. Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990). The Court may not reweigh evidence or substitute its judgment for that of the Commissioner and, even if the evidence

preponderates against the Commissioner’s factual findings, the Court must affirm if the decision is supported by substantial evidence. Winschel, 631 F.3d at 1178; Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983). II. PROCEDURAL BACKGROUND On May 27, 2021, Plaintiff filed an application for a period of disability and

disability insurance benefits, and an application for supplemental security income, alleging disability as of May 15, 2021. R. 17. Plaintiff’s applications were denied on initial review and reconsideration. Id. After the reconsideration denial, she requested a hearing before an Administrative Law Judge (ALJ). Id. The ALJ held a telephone hearing on March 13, 2023. Id. The ALJ issued an unfavorable decision on May 24, 2023 (R. 33),

and the Appeals Council denied Plaintiff’s request for review of the hearing decision, (R. 1). Thus, the hearing decision became the final decision of the Commissioner. See 42 U.S.C. § 405(g). III. THE ALJ’S DECISION Upon review of the record, the ALJ determined Plaintiff had severe impairments

of “left middle cerebral artery aneurysm and subarachnoid hemorrhage, subsequent cerebrovascular accident/right occipital lobe infarct, hypertension, mild obesity, and amnestic disorder.” R. 20. Despite these impairments, the ALJ determined Plaintiff has the residual functional capacity (RFC) to perform a range of “light work.” R. 24. The ALJ then found, based on testimony from the vocational expert (VE), that a significant number of jobs exist in the national economy Plaintiff could perform with her limitations.

R. 32. Thus, the ALJ determined Plaintiff was not disabled. R. 32–33. IV. DISCUSSION Plaintiff’s brief identifies one issue for this Court’s review: whether the ALJ erred by failing to order a neuropsychological consultative examination. Doc. 10 at 2. She argues that “a consultative examination was necessary for an informed decision, because

the medical evidence of record pertaining to [her] neurological impairments did not provide an adequate record for the ALJ to properly determine the nature and extent of [her] mental limitations and their impact on [her] RFC.” Id. at 12. The ALJ has a basic duty to develop a full and fair record. Graham v. Apfel, 129 F.3d 1420, 1422 (11th Cir. 1997) (citation omitted). This duty generally requires the ALJ

to assist, when necessary, in gathering medical evidence from Plaintiff’s medical sources and to order a consultative examination when one is necessary to make an informed decision. 20 C.F.R. § 404.1512(b). Nonetheless, “the claimant bears the burden of proving that he is disabled, and, consequently, he is responsible for producing evidence in support of his claim.” Ellison v. Barnhart, 355 F.3d 1272, 1276 (11th Cir. 2003) (citations omitted).

“Ordering a consultative examination is a discretionary matter for the ALJ and would be sought ‘to try to resolve an inconsistency in the evidence or when the evidence as a whole is insufficient to support a determination or decision’ on the claim.” Banks for Hunter v. Comm’r, Soc. Sec. Admin., 686 F. App’x 706, 713 (11th Cir. 2017) (quoting 20 C.F.R. § 416.919a(b)). Before the Court will remand a case for further development of the record, there must be a showing that the ALJ’s failure to develop the record led to

evidentiary gaps, which resulted in unfairness or clear prejudice. Graham, 129 F.3d at 1423 (citing Brown v. Shalala, 44 F.3d 931, 934–35 (11th Cir. 1995)). At a minimum, clear prejudice “requires a showing that the ALJ did not have all of the relevant evidence before him in the record . . . or that the ALJ did not consider all of the evidence in the record in reaching his decision.” Kelley v. Heckler, 761 F.2d 1538, 1540 (11th Cir. 1985)

(citation omitted).1

1 The Social Security regulations provide:

Situations that may require a consultative examination. We may purchase a consultative examination to try to resolve an inconsistency in the evidence, or when the evidence as a whole is insufficient to allow us to make a determination or decision on your claim. Some examples of when we might purchase a consultative examination to secure needed medical evidence, such as clinical findings, laboratory tests, a diagnosis, or prognosis, include but are not limited to: (1) The additional evidence needed is not contained in the records of your medical sources; (2) The evidence that may have been available from your treating or other medical sources cannot be obtained for reasons beyond your control, such as death or noncooperation of a medical source; (3) Highly technical or specialized medical evidence that we need is not available from your treating or other medical sources; or Upon review, the undersigned concludes that the ALJ fulfilled his obligation to develop a full and fair record in this case, and his failure to order a consultative

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