SLOCUM v. COMMISSIONER OF SOCIAL SECURITY

CourtDistrict Court, M.D. Georgia
DecidedJuly 3, 2025
Docket5:24-cv-00174
StatusUnknown

This text of SLOCUM v. COMMISSIONER OF SOCIAL SECURITY (SLOCUM v. COMMISSIONER OF SOCIAL SECURITY) is published on Counsel Stack Legal Research, covering District Court, M.D. Georgia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SLOCUM v. COMMISSIONER OF SOCIAL SECURITY, (M.D. Ga. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF GEORGIA MACON DIVISION

L.S. o/b/o Z.C., : : Plaintiff, : : v. : Case No. 5:24-cv-174-TES-CHW : COMMISSIONER OF SOCIAL SECURITY, : Social Security Appeal : Defendant. : :

REPORT AND RECOMMENDATION This is a review of a final decision of the Commissioner of the Social Security Administration denying B.S.’s application for benefits filed on behalf of Z.C., a minor. As discussed below, substantial evidence supports the Commissioner’s determination that the claimant does not qualify for disability benefits. Therefore, it is RECOMMENDED that Plaintiff’s motion to remand (Doc. 10) be DENIED and the Commissioner’s decision be AFFIRMED. I. Background Claimant Z.C. is a minor born on November 19, 2015. (R. 213). The claimant’s grandmother, B.S., applied for Title XVI disability benefits on the claimant’s behalf on April 19, 2022, alleging a disability onset date of May 28, 2021, due to seizures, speech impediment, post- traumatic stress disorder, and headaches. (R. 66, 146, 213, 228). After the application was denied initially and on reconsideration at the state agency level of review (Exs. B2A, B3A, B3B, B5B), Plaintiff, the claimant’s mother, requested further review before an administrative law judge (ALJ). (R. 78); (Ex. B6B). At a video hearing before the ALJ in June 2023, Plaintiff clarified that she filed for social security because the claimant had seizures and was “not learning what she’s supposed to learn and she forgets.” (R. 89–90). Following that hearing, the ALJ issued an unfavorable opinion, concluding that the claimant was not disabled. (R. 60). Plaintiff subsequently requested further

review before the Appeals Council, but in April 2024, the Appeals Council declined Plaintiff’s request for further administrative review. (R. 1). Plaintiff now seeks judicial review of the ALJ’s decision, arguing that the ALJ did not properly assess evidence in its finding that the claimant did not have a “marked” limitation in any domain and that new medical evidence presented to the appeals council warrants remand. As discussed below, the record supports neither of Plaintiff’s arguments. II. Standard of Review Judicial review of a decision of the Commissioner of Social Security is limited to a determination of whether the decision is supported by substantial evidence, as well as whether the Commissioner applied the correct legal standards. Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176,

1178 (11th Cir. 2011) (internal quotation and citation omitted). “Substantial evidence” is defined as “more than a scintilla,” and as “such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Id. The Eleventh Circuit has explained that reviewing courts “may not decide the facts anew, reweigh the evidence, or substitute our judgment for that of the [Commissioner].” Id. (citation omitted). Rather, if the Commissioner’s decision is supported by substantial evidence, the decision must be affirmed even if the evidence preponderates against it. Buckwalter v. Acting Comm’r of Soc. Sec., 5 F.4th 1315, 1320 (11th Cir. 2021). Consequently, the Court’s role in reviewing claims brought under the Social Security Act is quite narrow. The Commissioner’s findings of law are given less deference. Those, the Court will consider de novo. Harner v. Soc. Sec. Admin., Comm’r, 38 F.4th 892, 896 (11th Cir. 2022). III. Evaluation of Disability Persons under the age of 18 are disabled for purposes of receiving Title XVI benefits if

they have “a medically determinable physical or mental impairment, which results in marked and severe functional limitations, and 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 12 months.” 42 U.S.C. § 1382c(a)(3)(C)(i). When analyzing the issue of disability for persons under the age of 18, the ALJ uses a three-step sequential evaluation procedure. 20 C.F.R. § 416.924(a). At step one, the ALJ determines whether the child is engaged in substantial gainful activity. 20 C.F.R. § 416.924(b). At step two, if the child is not engaged in substantial gainful activity, then the ALJ determines whether the child has a medically determinable impairment or combination of impairments that is “severe.” 20 C.F.R. § 416.924(c). At step three, the ALJ determines whether the child's impairment or

combination of impairments meets or is medically or functionally equal to one of the listed impairments, and otherwise satisfies the relevant duration requirement. 20 C.F.R. § 416.924(d). To determine whether the child's impairment functionally equals a listed impairment, the ALJ must consider six “domains,” which are “broad areas of functioning intended to capture all of what a child can and cannot do.” 20 C.F.R. § 416.926a(b)(1). The six domains are: (1) acquiring and using information, (2) attending and completing tasks, (3) interacting and relating with others, (4) moving about and manipulating objects, (5) caring for yourself, and (6) health and physical well-being. 20 C.F.R. § 416.926a(b)(1)(i)-(vi). To satisfy the “functional equivalence” standard, the child must have either “marked” limitations in two domains or an “extreme” limitation in one domain. 20 C.F.R. § 416.926a(d). IV. Medical Record Plaintiff’s challenge in this case concerns the ALJ’s consideration of the claimant’s school

evaluations and psychoeducational results. Therefore, this medical summary focuses on the evaluations as they appear in the record. However, the entire medical record has been reviewed in preparation of this recommendation. The claimant has a history of seizures, headaches, and educational impairments. See (Ex. B3F). Treatment notes from Children’s Healthcare of Atlanta indicate in the seizure history section that the claimant had seizures as early as early as five months old. (R. 472). The first treatment notes that indicate an assessment of seizures are from March 2020. (R. 457). Treatment notes indicate further that by January 2021, the claimant had a history of seizures and headaches. (R. 451). Four times between January and April 2022. the claimant visited her neurologist, Dr. Abdul Qadir, who assessed the claimant with absence epileptic syndrome, intractable, without status

epilepticus. (R. 419, 421, 425–26). In June 2022, the claimant was admitted for inpatient monitoring for three days. (Ex. B5F). The record notes no seizures during the study and finds that the “long-term EEG in the awake, drowsy and asleep states is within normal limits for age.” (R. 485). Following the EEG, Dr. Qadir started the claimant on levocarnitine and continued Depakene, and subsequent treatment records indicate that the claimant has had no seizures since May 2022 (R.

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SLOCUM v. COMMISSIONER OF SOCIAL SECURITY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/slocum-v-commissioner-of-social-security-gamd-2025.