Shaw v. Commissioner of Social Security

CourtDistrict Court, W.D. North Carolina
DecidedJune 16, 2022
Docket3:20-cv-00713
StatusUnknown

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

Bluebook
Shaw v. Commissioner of Social Security, (W.D.N.C. 2022).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NORTH CAROLINA CHARLOTTE DIVISION 3:20-cv-00713-RJC

BRITTNEY SHAW, ) ) Plaintiff, ) ) v. ) ) ORDER COMMISSIONER OF SOCIAL SECURITY, ) ) Defendant. ) ) )

THIS MATTER comes before the Court on the Parties’ Cross Motions for Summary Judgment. (DEs 13, 15). Having fully considered the written arguments, administrative record, and applicable authority, the Court grants Plaintiff’s Motion for Summary Judgment and remands this matter for further proceedings consistent with this Order. I. BACKGROUND Plaintiff Brittany Shaw (“Shaw”) seeks judicial review of the Commissioner of Social Security’s (“Defendant” or “Commissioner”) denial of her social security claim. Shaw filed her application for disability insurance benefits on February 26, 2019, with an alleged onset date of October 1, 2012. (Tr.1 10). In denying Shaw’s social security claim, the ALJ conducted a five-step sequential evaluation. (Tr. 10–19). At step one, the ALJ found that Shaw had not engaged in substantial gainful activity since the application date. (Id. at 12). At step two, the ALJ found that Shaw had the following combination of severe impairments: rheumatoid arthritis (“RA”), lupus, Turner’s

1 Citations to “Tr.” throughout the Order refer to the administrative record. Syndrome/thyroid disorder, fibromyalgia, and asthma. (Id.). The ALJ also found that Shaw had the following non-severe impairment: mild depressive disorder. (Id.). At step three, the ALJ found that none of the impairments, or combinations of impairments, met or equaled the severity of a listed impairment. (Id. at 13). Before moving to step four, the ALJ found that Shaw had the residual functional capacity (“RFC”) to perform light work as explained below:

[T]he claimant has the residual functional capacity to perform light work as defined in 20 CFR 416.967(b) except frequent, but not constant pushing and pulling in the upper and lower extremities; frequent, but not constant reaching, handling, fingering. She must avoid concentrated exposure to extreme heat, humidity, hazards; fumes, odors, dusts, gases.

(Id. at 14). At step four, the ALJ found that Shaw could not perform any past relevant work but found at step five that Shaw could perform jobs that exist in significant numbers in the national economy. (Id. at 17–18). After exhausting her administrative remedies, Shaw brought the instant action for review of Defendant’s decision denying her application for disability insurance benefits under Title II of the Social Security Act. (DE 1). II. STANDARD OF REVIEW The Social Security Act, 42 U.S.C. § 405(g) and § 1383(c)(3), limits this Court’s review of a final decision of the Commissioner to: (1) whether substantial evidence supports the Commissioner’s decision, Richardson v. Perales, 402 U.S. 389, 390, 401 (1971); and (2) whether the Commissioner applied the correct legal standards. Hays v. Sullivan, 907 F.2d 1453, 1456 (4th Cir. 1990); see also Hunter v. Sullivan, 993 F.2d 31, 34 (4th Cir. 1992) (per curiam). The District Court does not review a final decision of the Commissioner de novo. Smith v. Schweiker, 795 F.2d 343, 345 (4th Cir. 1986); King v. Califano, 599 F.2d 597, 599 (4th Cir. 1979); Blalock v. Richardson, 483 F.2d 773, 775 (4th Cir. 1972). As the Social Security Act provides, “[t]he findings of the [Commissioner] as to any fact, if supported by substantial evidence, shall be conclusive.” 42 U.S.C. § 405(g). In Smith v. Heckler, 782 F.2d 1176, 1179 (4th Cir. 1986) (quoting Richardson v. Perales, 402 U.S. 389, 401 (1971)), the Fourth Circuit defined “substantial evidence” as: Substantial evidence has been defined as being “more than a scintilla and do[ing] more than creat[ing] a suspicion of the existence of a fact to be established. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”

See also Seacrist v. Weinberger, 538 F.2d 1054, 1056–57 (4th Cir. 1976) (“We note that it is the responsibility of the [Commissioner] and not the courts to reconcile inconsistencies in the medical evidence.”). The Fourth Circuit has long emphasized that it is not for a reviewing court to weigh the evidence again, nor to substitute its judgment for that of the Commissioner, assuming the Commissioner’s final decision is supported by substantial evidence. Hays v. Sullivan, 907 F.2d at 1456; see also Smith v. Schweiker, 795 F.2d at 345; and Blalock v. Richardson, 483 F.2d at 775. Indeed, this is true even if the reviewing court disagrees with the outcome—so long as there is “substantial evidence” in the record to support the final decision below. Lester v. Schweiker, 683 F.2d 838, 841 (4th Cir. 1982). III. DISCUSSION OF CLAIM Shaw raises four challenges: (1) the ALJ misevaluated Shaw’s limitations from RA when assessing the RFC, (2) the ALJ misevaluated the medical opinion of treating physician Dr. Brendese, (3) the ALJ improperly evaluated listing 14.09B at step three of the analysis, and (4) the structure of the Social Security Administration is constitutionally invalid. The Court grants remand based on Shaw’s third challenge. A necessary predicate to engaging in substantial evidence review is a record of the basis for the ALJ’s ruling. See Gordon v. Schweiker, 725 F.2d 231, 235 (4th Cir.1984). At step three, this requires the ALJ to explain why the record evidence does not meet a relevant listing. Radford v. Colvin, 734 F.3d 288, 295 (4th Cir. 2013). When the ALJ’s decision is “devoid of reasoning” or where the ALJ “summarily concluded that [claimant’s] impairment did not meet or equal a listed impairment” with no explanation, the Fourth Circuit has held that remand is appropriate. Id.

This is because the “insufficient legal analysis makes it impossible for a reviewing court to evaluate whether substantial evidence supports the ALJ’s findings.” Id. (citing Cook v. Heckler, 783 F.2d 1168, 1173 (4th Cir.1986)). The Fourth Circuit has also held that a “full explanation by the ALJ is particularly important [when claimant’s] medical record includes a fair amount of evidence supportive of his claim.” Radford, 734 F.3d at 295 (citing Murphy v.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Sullivan v. Hudson
490 U.S. 877 (Supreme Court, 1989)
Shalala v. Schaefer
509 U.S. 292 (Supreme Court, 1993)
Jimmy Radford v. Carolyn Colvin
734 F.3d 288 (Fourth Circuit, 2013)

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Bluebook (online)
Shaw v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shaw-v-commissioner-of-social-security-ncwd-2022.