Sullivan v. Commissioner of Social Security

District Court, W.D. North Carolina·Decided August 21, 2024·No. 1:23-cv-00127·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF NORTH CAROLINA ASHEVILLE DIVISION 1:23-cv-00127-MOC-WCM

JEANNE SULLIVAN, ) ) Plaintiff, ) MEMORANDUM AND ) RECOMMENDATION v. ) ) COMMISSIONER OF THE SOCIAL ) SECURITY ADMINISTRATION, ) ) Defendant. ) _______________________________ )

This matter has been referred to the undersigned pursuant to 28 U.S.C. § 636 for the entry of a recommendation. I. Procedural Background In October of 2020, Plaintiff Jeanne Sullivan (“Plaintiff”) filed an application for disability insurance benefits. Transcript of the Administrative Record (“AR”) 212-213. Plaintiff alleges disability beginning on April 1, 2020. AR 223. On August 9, 2022, following an administrative hearing at which Plaintiff appeared and testified, an Administrative Law Judge (“ALJ”) issued an unfavorable decision. AR 14-36. That decision is the Commissioner’s final decision for purposes of this action. II. The ALJ’s Decision The ALJ found that Plaintiff had the severe impairments of “cervical

spine disorder, right shoulder impairment, left hip osteoarthritis, and lumbar spine disorder.” AR 19. After determining that Plaintiff’s impairments did not meet or medically equal any listed impairment, the ALJ found that Plaintiff had the residual functional capacity (“RFC”):

to perform medium work… except never climb ropes, ladders and scaffolds. She can occasionally climb ramps/stairs, engage in balancing, stooping, kneeling, crouching and crawling. The claimant is limited to occasional exposure to hazards, dangerous moving machinery, and unprotected heights. The claimant is limited to occasional exposure to temperature extremes, humidity/wetness. She is frequently limited to reaching with right upper extremity; overhead reaching with left upper extremity; and handling and fingering. AR 21. Applying this RFC, the ALJ found that Plaintiff had the ability to perform certain jobs that exist in significant numbers in the national economy such that Plaintiff was not disabled during the relevant period. AR 28-29. III. Plaintiff’s Allegation of Error Plaintiff contends that, when developing her RFC, the ALJ failed to conduct a proper function-by-function analysis and therefore failed to explain how the evidence supported his conclusions regarding Plaintiff’s ability to lift, carry, reach, handle, finger, sit, stand, and walk. IV. Standard of Review A claimant has the burden of proving that he or she suffers from a

disability, which is defined as a medically determinable physical or mental impairment lasting at least 12 months that prevents the claimant from engaging in substantial gainful activity. 20 C.F.R. §§ 404.1505; 416.905. The regulations require the Commissioner to evaluate each claim for benefits using

a five-step sequential analysis. 20 C.F.R. §§ 404.1520; 416.920. The burden rests on the claimant through the first four steps to prove disability. Monroe v. Colvin, 826 F.3d 176, 179 (4th Cir. 2016). If the claimant is successful at these steps, then the burden shifts to the Commissioner to prove at step five

that the claimant can perform other work. Mascio v. Colvin, 780 F.3d 632, 635 (4th Cir. 2015); Monroe, 826 F.3d at 180. Under 42 U.S.C. § 405(g), judicial review of a final decision of the Commissioner denying disability benefits is limited to whether substantial

evidence exists in the record as a whole to support the Commissioner’s findings, and whether the Commissioner’s final decision applies the proper legal standards. Hines v. Barnhart, 453 F.3d 559, 561 (4th Cir. 2006). When a federal district court reviews the Commissioner’s decision, it does not “re-weigh

conflicting evidence, make credibility determinations, or substitute [its] judgment for that of the [Commissioner].” Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996). Accordingly, the issue before the Court is not whether Plaintiff is disabled but, rather, whether the Commissioner’s decision that she is not disabled is supported by substantial evidence in the record and based on the

correct application of the law. Id. V. Discussion “A social security claimant’s RFC represents ‘the most [a claimant] can still do despite [his or her] limitations.’” Dowling v. Commissioner of Social

Security Administration, 986 F.3d 377, 387 (4th Cir. 2021) (quoting 20 C.F.R. § 416.945(a)(1)) (modification added). “Evaluating an RFC requires an ALJ to consider all of the claimant’s physical and mental impairments, severe and otherwise, and determine, on a function-by-function basis, how they affect [his

or her] ability to work.” Id. (quoting Thomas v. Berryhill, 916 F.3d 307, 311 (4th Cir. 2019) (quoting Monroe v. Colvin, 826 F.3d 176, 188 (4th Cir. 2016)) (modification added). In Dowling, the Fourth Circuit emphasized that this function-by-

function assessment of a claimant’s abilities must be based on the correct regulatory framework, i.e., that set forth in 20 C.F.R. §§ 404.1545 and/or 416.945 and SSR 96-8p, 1996 WL 374184 (July 2, 1996).1

1 20 C.F.R. § 404.1545 sets out the evaluation process of a claimant’s physical abilities relative to claims for disability insurance benefits, while 20 C.F.R. § 416.945 sets out an identical process relative to claims for supplemental security income. Pursuant to SSR 96-8p, an ALJ’s RFC assessment must include an evaluation of the claimant’s ability to perform certain physical functions.

“These functions are: ‘sitting, standing, walking, lifting, carrying, pushing, pulling, or other physical functions [that] may reduce [a claimant’s] ability to do past work and other work.’” 986 F.3d at 387 (quoting 20 C.F.R. § 416.945(b)). Because the ALJ in Dowling failed to cite 20 C.F.R. § 416.945 and SSR 96-8p,

“did not indicate that his RFC assessment was rooted in a function-by-function analysis,” and instead only conducted an evaluation of the claimant’s symptoms (a related, but “separate and distinct inquiry”), the matter was remanded. Id. at 387.

Here, the ALJ referenced SSR 96-8p and 20 C.F.R. §404.1545

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