Small v. Commissioner of Social Security Administration

CourtDistrict Court, W.D. Virginia
DecidedAugust 30, 2024
Docket5:23-cv-00045
StatusUnknown

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

Bluebook
Small v. Commissioner of Social Security Administration, (W.D. Va. 2024).

Opinion

Al HARRISONBURG, VA FILED IN THE UNITED STATES DISTRICT COURT August 30, 2024 FOR THE WESTERN DISTRICT OF VIRGINIA LAURA □ oe CLER Harrisonburg Division bye Bre □□□□□□ DEPUTY □□□□□ KATIE S., ) Plaintiff, ) Civil Action No. 5:23-cv-00045 ) v. ) REPORT & RECOMMENDATION ) MARTIN O’MALLEY, ) By: Joel C. Hoppe Commissioner of Social Security, ) United States Magistrate Judge Defendant. ) Plaintiff Katie S. asks this Court to review the Commissioner of Social Security’s (“Commissioner”) final decision denying her application for disability insurance benefits (“DIB”) under Title II of the Social Security Act, 42 U.S.C. §§ 401-434. The case is before me by referral under 28 U.S.C. § 636(b)(1)(B). Having considered the administrative record (“R.”), ECF No. 8; the parties’ briefs, ECF Nos. 12, 19, 20; and the applicable law, I find that the Commissioner’s final decision is supported by substantial evidence. Accordingly, I respectfully recommend that the presiding District Judge affirm the decision. I. Standard of Review The Social Security Act authorizes this Court to review the Commissioner’s final decision that a person is not entitled to disability benefits. 42 U.S.C. § 405(g); see also Hines v. Barnhart, 453 F.3d 559, 561 (4th Cir. 2006). The Court’s role, however, is limited—it may not “reweigh conflicting evidence, make credibility determinations, or substitute [its] judgment” for that of agency officials. Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012). Instead, a court reviewing the merits of the Commissioner’s final decision asks only whether the Administrative Law Judge (“ALJ”) applied the correct legal standards and whether substantial evidence supports the ALJ’s factual findings. Meyer v. Astrue, 662 F.3d 700, 704 (4th Cir. 2011); see Riley v. Apfel, 88 F. Supp. 2d 572, 576 (W.D. Va. 2000) (citing Melkonyan v. Sullivan, 501 U.S. 89 (1991)).

“Substantial evidence” means “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971). It is “more than a mere scintilla” of evidence, id., but not necessarily “a large or considerable amount of evidence,” Pierce v. Underwood, 487 U.S. 552, 565 (1988). Substantial evidence review

considers the entire record and not just the evidence cited by the ALJ. See Universal Camera Corp. v. NLRB, 340 U.S. 474, 487–89 (1951); Gordon v. Schweiker, 725 F.2d 231, 236 (4th Cir. 1984). Ultimately, this Court must affirm the ALJ’s factual findings if “conflicting evidence allows reasonable minds to differ as to whether a claimant is disabled.” Johnson v. Barnhart, 434 F.3d 650, 653 (4th Cir. 2005) (per curiam). However, “[a] factual finding by the ALJ is not binding if it was reached by means of an improper standard or misapplication of the law.” Coffman v. Bowen, 829 F.2d 514, 517 (4th Cir. 1987). A person is “disabled” within the meaning of the Act if he or she is unable to engage in “any substantial gainful activity by reason of any medically determinable physical or mental impairment 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. § 423(d)(1)(A). Social Security ALJs follow a five-step process to determine whether a claimant is disabled. The ALJ asks, in sequence, whether the claimant (1) is working; (2) has a severe impairment that satisfies the Act’s duration requirement; (3) has an impairment that meets or equals an impairment listed in the Act’s regulations; (4) can return to his or her past relevant work based on his or her residual functional capacity; and, if not (5) whether he or she can perform other work. See Heckler v. Campbell, 461 U.S. 458, 460–62 (1983); Lewis v. Berryhill, 858 F.3d 858, 861 (4th Cir. 2017); 20 C.F.R. § 404.1520(a)(4).1 The claimant bears the burden of proof through step four. Lewis, 858 F.3d at 861. At step five, the burden shifts to the agency to prove that the claimant is not disabled. See id. II. Procedural History

This is Katie’s second application for disability benefits. See R. 87. In January 2018, Katie filed for benefits alleging that she had been disabled since October 2017 because of obesity, chronic anemia with chronic vaginal bleeding and chronic pain, and anxiety with agoraphobia, among other impairments. See R. 64, 67. On September 5, 2019, ALJ Harry Chambers issued a written decision finding that, notwithstanding her severe chronic medical impairments, Katie still could perform certain unskilled occupations existing in the national economy. See R. 68–69, 73–74. ALJ Chambers’s decision is the final decision of the Commissioner that Katie was “not disabled” on or before September 5, 2019. See R. 88; 20 C.F.R. § 404.955. In August 2020, Katie filed for DIB again, alleging she had been disabled since

September 6, 2019, see R. 235–37, because of depression, a learning disability, diabetes, an anxiety disorder, degenerative disc disease, a back problem, sciatica, thyroid disorder, polycystic ovarian syndrome (“PCOS”), and chronic pain syndrome, see R. 87. She was thirty-one years old in September 2019, id., making her a “younger person” under the regulations, 20 C.F.R. § 404.1563(c). Virginia Disability Determination Services (“DDS”) denied her claim initially in July 2021, R. 86–97, and upon reconsideration in December 2021, R. 98–107. On December 6,

1 Unless otherwise noted, citations to the Code of Federal Regulations refer to the version in effect on the date of the Commissioner’s final written decision. 2022, Katie appeared with counsel and testified at a hearing before ALJ Brian Rippel. R. 42–54. A vocational expert (“VE”) also testified at the hearing. R. 54–60. ALJ Rippel issued an unfavorable decision on December 28, 2022. R. 18–34. At step one, he found that Katie had not engaged in substantial gainful activity since September 6, 2019, and that she met the Act’s insured-status requirements through September 30, 2021.2 R. 20. At

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Heckler v. Campbell
461 U.S. 458 (Supreme Court, 1983)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Coffman v. Bowen
829 F.2d 514 (Fourth Circuit, 1987)
Meyer v. Astrue
662 F.3d 700 (Fourth Circuit, 2011)
Riley v. Apfel
88 F. Supp. 2d 572 (W.D. Virginia, 2000)
Melkonyan v. Sullivan
501 U.S. 89 (Supreme Court, 1991)
Bonnilyn Mascio v. Carolyn Colvin
780 F.3d 632 (Fourth Circuit, 2015)
George Monroe v. Carolyn Colvin
826 F.3d 176 (Fourth Circuit, 2016)
Stacy Lewis v. Nancy Berryhill
858 F.3d 858 (Fourth Circuit, 2017)
Brown v. Commissioner Social Security Administration
873 F.3d 251 (Fourth Circuit, 2017)
Billie J. Woods v. Nancy Berryhill
888 F.3d 686 (Fourth Circuit, 2018)
Nikki Thomas v. Nancy Berryhill
916 F.3d 307 (Fourth Circuit, 2019)

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Bluebook (online)
Small v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/small-v-commissioner-of-social-security-administration-vawd-2024.