Simpson v. Kijakazi

CourtDistrict Court, E.D. North Carolina
DecidedFebruary 11, 2022
Docket7:20-cv-00092
StatusUnknown

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

Bluebook
Simpson v. Kijakazi, (E.D.N.C. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA SOUTHERN DIVISION No. 7:20-CV-92-RJ KENNETH E. SIMPSON, JR., Plaintiff/Claimant, ORDER KILOLO KIJAKAZI, Acting Commissioner of Social Security, Defendant.

This matter is before the court on the parties’ cross-motions for judgment on the pleadings [DE-23, -30] pursuant to Fed. R. Civ. P. 12(c). Claimant Kenneth E. Simpson, Jr. (“Claimant”) filed this action pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3) seeking judicial review of the denial of his application for Supplemental Security Income (“SSI”) payments. The time for filing responsive briefs has expired, and the pending motions are ripe for adjudication. Having carefully reviewed the administrative record and the motions and memoranda submitted by the parties, Claimant’s Motion for Judgment on the Pleadings is denied, Defendant’s Motion for Judgment on the Pleadings is allowed, and the final decision of the Acting Commissioner is affirmed. I. STATEMENT OF THE CASE Claimant protectively filed an application for SSI on September 27, 2016, alleging disability beginning October 31, 2015. (R. 13). His claim was denied initially and upon reconsideration. (R. 13, 59-92). A hearing before the Administrative Law Judge (“ALJ”) was held on February 27, 2019, at which Claimant, represented by counsel, and a vocational expert (“VE”) appeared and testified. (R. 29-53). Claimant amended his alleged onset date to April 18,

2017. (R. 13). On April 23, 2019, the ALJ issued a decision denying Claimant’s request for benefits. (R. 10-28). On April 1, 2020, the Appeals Council denied Claimant’s request for review. (R. 1-6). Claimant then filed a complaint in this court seeking review of the now-final administrative decision. II. STANDARD OF REVIEW The scope of judicial review of a final agency decision regarding disability benefits under the Social Security Act (“Act”), 42 U.S.C. § 301 ef seq., is limited to determining whether substantial evidence supports the Commissioner’s factual findings and whether the decision was reached through the application of the correct legal standards. See Coffman v. Bowen, 829 F.2d 514, 517 (4th Cir. 1987). “The findings of the Commissioner . . . as to any fact, if supported by substantial evidence, shall be conclusive ... .” 42 U.S.C. § 405(g). Substantial evidence is “evidence which a reasoning mind would accept as sufficient to support a particular conclusion.” Laws v. Celebrezze, 368 F.2d 640, 642 (4th Cir. 1966). While substantial evidence is not a “large or considerable amount of evidence,” Pierce v. Underwood, 487 U.S. 552, 565 (1988), it is “more than a mere scintilla . . . and somewhat less than a preponderance.” Laws, 368 F.2d at 642. “In reviewing for substantial evidence, [the court should not] undertake to re-weigh conflicting evidence, make credibility determinations, or substitute [its] judgment for that of the {Commissioner].” Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001) (quoting Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996), superseded by regulation on other grounds, 20 C.FR. § 416.927(d)(2)). Rather, in conducting the “substantial evidence” inquiry, the court’s review is limited to whether the ALJ analyzed the relevant evidence and sufficiently explained his or her findings and rationale in crediting the evidence. Sterling Smokeless Coal Co. v. Akers, 131 F.3d 438, 439-40 (4th Cir. 1997).

Ill. DISABILITY EVALUATION PROCESS The disability determination is based on a five-step sequential evaluation process as set forth in 20 C.F.R. § 416.920 under which the ALJ is to evaluate a claim: The claimant (1) must not be engaged in “substantial gainful activity,” i.e., currently working; and (2) must have a “severe” impairment that (3) meets or exceeds [in severity] the “listings” of specified impairments, or is otherwise incapacitating to the extent that the claimant does not possess the residual functional capacity to (4) perform . . . past work or (5) any other work. Albright v. Comm’r of the SSA, 174 F.3d 473, 475 n.2 (4th Cir. 1999). “If an applicant’s claim fails at any step of the process, the ALJ need not advance to the subsequent steps.” Pass v. Chater, 65 F.3d 1200, 1203 (4th Cir. 1995) (citation omitted). The burden of proof and production during the first four steps of the inquiry rests on the claimant. Jd. At the fifth step, the burden shifts to the ALJ to show that other work exists in the national economy which the claimant can perform. /d. When assessing the severity of mental impairments, the ALJ must do so in accordance with the “special technique” described in 20 C.F.R. § 416.920a(b)(c). This regulatory scheme identifies four broad functional areas in which the ALJ rates the degree of functional limitation resulting from a claimant’s mental impairment(s): understanding, remembering, or applying information; interacting with others; concentrating, persisting, or maintaining pace; and adapting or managing oneself. Id. § 416.920a(c)(3). The ALJ is required to incorporate into his written decision pertinent findings and conclusions based on the “special technique.” Id. § 416.920a(e)(3). In this case, Claimant alleges the ALJ erred in evaluating Claimant’s major depressive disorder and related non-exertional limitations. Pl.’s Mem. [DE-24] at 19-30.!

The page numbers referenced in Claimant’s memorandum correspond to the page numbers in the CM/ECF footer where they differ from the document’s internal page numbers.

IV. ALJ’S FINDINGS Applying the above-described sequential evaluation process, the ALJ found Claimant “not disabled” as defined in the Act. At step one, the ALJ found Claimant had not engaged in substantial gainful activity since April 18, 2017, the amended alleged onset date. (R. 15). Next, the ALJ determined Claimant had the following severe impairments: low back pain, diabetes mellitus with neuropathy, osteoarthritis of the left knee with tibial plateau deformity, osteoarthritis of the right hip, hypertension, and history of shortness of breath upon exertion. (R. 15-16). The ALJ also found Claimant’s alcohol use disorder, depression, and anxiety were nonsevere. (R. 16).

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Simpson v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/simpson-v-kijakazi-nced-2022.