Smith v. Social Security Administration

CourtDistrict Court, W.D. Louisiana
DecidedAugust 12, 2024
Docket6:22-cv-06220
StatusUnknown

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

Bluebook
Smith v. Social Security Administration, (W.D. La. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA LAFAYETTE DIVISION

HEMMY SMITH CASE NO. 6:22-CV-06220

VERSUS JUDGE ROBERT R. SUMMERHAYS

COMMISSIONER OF SOCIAL MAGISTRATE JUDGE DAVID J. AYO SECURITY ADMINISTRATION

REPORT AND RECOMMENDATION Before this Court is an appeal of the Commissioner’s finding of non-disability. This matter was referred to the undersigned for issuance of a report and recommendation pursuant to 28 U.S.C. § 636. After review of the administrative record, the parties’ briefs, and the applicable law, and for the reasons set forth below, it is recommended that the Commissioner’s decision be VACATED and this matter be REMANDED for further consideration pursuant to the fourth sentence of 42 U.S.C. § 405(g). Administrative Proceedings Claimant Hemmy Smith fully exhausted her remedies before initiating this action. Claimant filed applications for Disability Insurance Benefits and Supplemental Security Income benefits, alleging disability beginning on February 24, 2020. (Rec. Doc. 4-1 at pp. 113-14, 203). Her applications were denied. (Id. at pp. 103-112, 123-127). Claimant requested rehearing. (Id. at pp. 133-136). Her rehearing requests were denied. (Id. at pp. 137-142). Claimant requested a hearing before an administrative law judge (“ALJ”). (Id. at pp. 143-180). Her request was granted, and a hearing was scheduled for January 12, 2022. (Id. at pp. 181-198). By letter dated January 10, 2022, Claimant requested a hearing via video-teleconference (“Zoom”). (Id. at p. 279). Pursuant to COVID-19 protocols still in place at that time, the January 12 hearing was conducted via telephone before ALJ Carol Latham. (Id. at pp. 25–38). No mention was made of Claimant’s request for a Zoom hearing. Neither Claimant nor her counsel objected to the conduct of the hearing by telephone. (Id. at p. 76). The ALJ issued her decision on April 25, 2022, finding that Claimant was not disabled within the meaning of the Social Security Act, 42 U.S.C. §§ 405(g), 1383(c)(3), during the relevant period of February 24, 2020 through the date of decision. (Rec. Doc. 4-1

at p. 38). Claimant applied to the Social Security Council for review, submitting evidence of hospitalizations occurring both immediately before and after the ALJ’s decision, but that application was denied on October 25, 2022. (Id. at pp. 1-5). Therefore, the ALJ’s decision became the Commissioner’s final decision. Higginbotham v. Barnard, 405 F.3d 332, 336 (5th Cir. 2005). There being a final decision by the Commissioner in this case, review by this district court is proper under Section 1631(c)(3) of the Social Security Act and 42 U.S.C. §1383(c). Relevant Factual Background Claimant was born on November 5, 1979. (Rec. Doc. 4-1 at p. 36). At the time of the ALJ’s decision, she was 40 years old. (Id.). She has a high school education and previously held jobs as a kitchen helper and line cook. (Id. at p. 226). She alleges that she has been disabled since February 24, 2020 due to focal seizures, generalized epilepsy, migraines, anxiety, and mesial temporal sclerosis. (Id. at pp. 103, 284). Claimant alleges the ALJ’s ruling is not supported by substantial evidence in this case. Specifically, she asserts that medical records demonstrate that her seizures occur with such frequency that she would be absent from work “at least two days a month” with no advance warning and off task approximately 15% of the time while at work. (Rec. Doc.

10 at pp. 1-2). Claimant also points out that medical records of her April 12-18, 2022 hospitalization show a general intensification of her seizures since the date of her application. (Id.). Entitlement to Benefits The Disability Insurance Benefit program provides income to individuals who are forced into involuntary, premature retirement, provided they are both insured and disabled, regardless of indigence. 42 U.S.C. § 423(a); Smith v. Berryhill, 587 U.S. 471, 139 S. Ct. 1765, 1772 (2019) (quoting Bowen v. Galbreath, 485 U.S. 74, 75 (1988)). Supplemental

Security Income provides income to individuals who meet certain income and resource requirements, have applied for benefits, and are disabled. 42 U.S.C. § 1382(a)(1), (2); Berryhill, supra. A person is “disabled” within the meaning of the Act when he or she is unable to engage in substantial gainful activity by reason of a medically determinable physical or mental impairment which can be result in death or which has lasted or can be expected to last for a continuous period of not less than twelve months.

42 U.S.C. § 1382c(a)(3)(A). A claimant is disabled if his physical or mental impairment or impairments are so severe that he is unable to perform previous work and considering his age, education, and work experience, cannot participate in any other kind of substantial gainful work that exists in significant numbers in the national economy, regardless of whether such work exists in the are in which the claimant lives, whether a specific job vacancy exists, or whether the claimant would be hired if he applied for work. 42 U.S.C. § 1382c(a)(3)(B). Standards of Review Judicial review of the Commissioner’s denial of disability benefits is limited to determining whether substantial evidence supports the decision and whether the proper legal standards were used in evaluating the evidence. Martinez v. Chater, 64 F.3d 172, 173 (5th Cir. 1995); Villa v. Sullivan, 895 F.2d 1019, 1021 (5th Cir. 1990). The Fifth Circuit defines the term “substantial evidence” as more than a scintilla, less than a preponderance, and is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. It must do more than create a suspicion of the existence of the fact to be established, but “no substantial evidence” will be found only where there is a “conspicuous absence of credible choices” or “no contrary medical evidence.”

Homes v. Heckler, 707 F.2d 162, 164 (5th Cir. 1983). If the Commissioner’s findings are supported by substantial evidence, they are conclusive and must be affirmed. 42 U.S.C. § 405(g); Martinez, 64 F.3d at 173. A district court presented with an appeal of the Commissioner’s findings must carefully review the entire record of the case but must refrain from reweighing the evidence or substituting its judgment for that of the Commissioner. Villa, 895 F.2d at 1022, Hollis v.

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