Simmons v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedSeptember 22, 2025
Docket7:24-cv-00984
StatusUnknown

This text of Simmons v. Social Security Administration, Commissioner (Simmons 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
Simmons v. Social Security Administration, Commissioner, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA WESTERN DIVISION

DAVID SIMMONS, ) ) Plaintiff, ) ) v. ) Case No.: 7:24-cv-984-AMM ) SOCIAL SECURITY ) ADMINISTRATION, ) Commissioner, ) ) Defendant. )

MEMORANDUM OF DECISION Plaintiff David Simmons brings this action pursuant to the Social Security Act (the “Act”), seeking review of the decision of the Commissioner of Social Security (“Commissioner”) denying his claim for a period of disability and disability insurance benefits (“benefits”). See 42 U.S.C. § 405(g). Based on the court’s review of the record, the court AFFIRMS the decision of the Commissioner. I. Introduction On May 16, 2022, Mr. Simmons protectively filed an application for benefits under Title II of the Act, alleging disability beginning January 8, 2021. R. 17, 71– 77, 175–76. Mr. Simmons alleges disability due to: sleep apnea; high blood pressure; congestive heart failure; impairments concerning his feet, right shoulder, and right arm; shortness of breath; and fluid retention. R. 71. The Social Security Administration (“SSA”) initially denied Mr. Simmons’s application on December 28, 2022, and again upon reconsideration on August 11,

2023. R. 17, 71–86. On September 11, 2023, Mr. Simmons filed a request for a hearing before an Administrative Law Judge (“ALJ”). R. 17, 122–23. That request was granted. R. 132–34. Mr. Simmons received a telephone hearing before ALJ

Sheila E. McDonald on February 8, 2024. R. 17, 38–70. On March 22, 2024, ALJ McDonald issued a decision, finding that Mr. Simmons was not disabled from January 8, 2021, through the date of the decision. R. 14–30. Mr. Simmons was forty- five years old at the time of the ALJ decision. R. 28, 30.

Mr. Simmons appealed to the Appeals Council, which denied his request for review on June 25, 2024. R. 1–3. After the Appeals Council denied Mr. Simmons’s request for review, R. 1–3, the ALJ’s decision became the final decision of the

Commissioner and subject to district court review. On July 22, 2024, Mr. Simmons sought this court’s review of the ALJ’s decision. See Doc. 1. II. The ALJ’s Decision The Act establishes a five-step test for the ALJ to determine disability. 20

C.F.R. § 404.1520. First, the ALJ must determine whether the claimant is engaging in substantial gainful activity. 20 C.F.R. § 404.1520(a)(4)(i). “Substantial work activity is work activity that involves doing significant physical or mental activities.”

20 C.F.R. § 404.1572(a). “Gainful work activity” is work that is done “for pay or profit.” 20 C.F.R. § 404.1572(b). If the ALJ finds that the claimant engages in substantial gainful activity, then the claimant cannot claim disability. 20 C.F.R. §

404.1520(b). Second, the ALJ must determine whether the claimant has a medically determinable impairment or a combination of medical impairments that significantly limits the claimant’s ability to perform basic work activities. 20 C.F.R. §

404.1520(a)(4)(ii), (c). Absent such impairment, the claimant may not claim disability. 20 C.F.R. § 404.1520(a)(4)(ii), (c). Third, the ALJ must determine whether the claimant’s impairment meets or medically equals the criteria of an impairment listed in 20 C.F.R. § 404, Subpart P, Appendix 1. See 20 C.F.R. §§

404.1520(a)(4)(iii), 404.1520(d), 404.1525, 404.1526. If such criteria are met, the claimant is declared disabled. 20 C.F.R. § 404.1520(a)(4)(iii). If the claimant does not fulfill the requirements necessary to be declared

disabled under the third step, the ALJ still may find disability under the next two steps of the analysis. The ALJ must first determine the claimant’s residual functional capacity, which refers to the claimant’s ability to work despite his impairments. 20 C.F.R. §§ 404.1520(e), 404.1545. In the fourth step, the ALJ determines whether the

claimant has the residual functional capacity to perform past relevant work. 20 C.F.R. § 404.1520(a)(4)(iv). If the ALJ determines that the claimant is capable of performing past relevant work, then the claimant is deemed not disabled. 20 C.F.R.

§ 404.1520(a)(4)(iv). If the ALJ finds the claimant unable to perform past relevant work, then the analysis proceeds to the fifth and final step. 20 C.F.R. § 404.1520(a)(4)(v). In this step, the ALJ must determine whether the claimant is able

to perform any other work commensurate with his residual functional capacity, age, education, and work experience. 20 C.F.R. § 404.1520(g)(1). Here, the burden of proof shifts from the claimant to the Commissioner to prove the existence, in

significant numbers, of jobs in the national economy that the claimant can do given his residual functional capacity, age, education, and work experience. 20 C.F.R. §§ 404.1520(g)(1), 404.1560(c). The ALJ determined that Mr. Simmons would meet the insured status

requirements of the Act through December 31, 2026. R. 17, 19. Next, the ALJ found that Mr. Simmons “has not engaged in substantial gainful activity since January 8, 2021, the alleged onset date.” R. 19 (emphasis omitted). The ALJ decided that Mr.

Simmons had the following severe impairments: status post arthroscopy of the right knee with reconstruction; obesity; arthritis of the right shoulder; chronic obstructive pulmonary disease (“COPD”); anxiety; and depression. R. 19. The ALJ found that Mr. Simmons had “nonsevere” impairments that do not cause more than minimal

work-related limitations: congestive heart failure; hypertension; obstructive sleep apnea; and diabetes. R. 20. Overall, the ALJ determined that Mr. Simmons “does not have an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments” to support a finding of disability. R. 20 (emphasis omitted).

The ALJ found that Mr. Simmons’s “statements concerning the intensity, persistence[,] and limiting effects of these symptoms are not entirely consistent with the medical evidence and other evidence in the record.” R. 23. The ALJ found that

Mr. Simmons “has the residual functional capacity to perform sedentary work” with certain limitations. R. 22 (emphasis omitted). The ALJ determined that Mr. Simmons can: occasionally operate foot controls with his right lower extremity; occasionally climb ramps and stairs, stop, kneel, and crouch; frequently reach

overhead with his right upper extremity; and occasionally be exposed to extremes of cold and full body vibration as well as atmospheric conditions such as dusts, odors, fumes, and pulmonary irritants. R. 22. The ALJ determined that Mr. Simmons

cannot: climb ladders, ropes, or scaffolds; crawl; or be exposed to hazards such as unprotected heights and hazardous machinery. R. 22.

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