Taylor v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedAugust 14, 2025
Docket3:23-cv-01212
StatusUnknown

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

Bluebook
Taylor v. Social Security Administration, Commissioner, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA NORTHWESTERN DIVISION ELIZABETH TAYLOR, ) ) Plaintiff, ) ) v. ) Case No.: 3:23-cv-1212-LCB ) FRANK BISIGNANO, ) Commissioner, Social Security ) Administration, ) ) Defendant. )

MEMORANDUM OPINION

On September 13, 2023, Claimant Elizabeth Taylor filed a complaint seeking judicial review of an adverse decision of the Commissioner of the Social Security Administration (“the Commissioner”) pursuant to 42 U.S.C. § 405(g). (Doc. 1). The Commissioner filed an answer and a copy of the administrative record on November 13, 2023. (Doc. 8). Taylor filed a brief in support of her position on December 13, 2023, and the Commissioner filed a response on February 2, 2024. (Docs. 10, 13). Taylor did not file a reply brief. Accordingly, the issues are now fully briefed, and Taylor’s case is ripe for review. For the reasons below, the Commissioner’s final decision is due to be affirmed. I. BACKGROUND On November 10, 2020, Taylor filed an application for a period of disability and disability insurance benefits, alleging disability beginning on May 30, 2018. (Tr. 136, 374-80). These claims were denied initially on March 24, 2021, and denied

again upon reconsideration on April 12, 2022. (Tr. 136–44; 146–155). Thereafter, Taylor then requested a hearing before an Administrative Law Judge, Judge Clarence Guthrie (“the ALJ”), who held a telephone hearing on January 4, 2022. (Tr.

108–35). An impartial vocational expert (“VE”) testified at this hearing. (Tr. 110). The ALJ subsequently issued an unfavorable decision. (See Doc. 13 (citing Tr. 19– 76)). Taylor requested review of the ALJ’s decision by the Appeals Council; on June 23, 2022, the Appeals Council vacated the ALJ’s decision, remanding the case back

to the ALJ. (Tr. 177-82). A second administrative hearing was held by the ALJ on January 17, 2023. (Tr. 79–107). On March 20, 2023, the ALJ again issued an unfavorable position. (Tr. 11–36). Though Taylor sought review by the Appeals

Council a second time, this request was denied and the ALJ’s decision became the Commissioner’s final decision. (Tr. 1–7). This lawsuit followed. II. THE ALJ’S DECISION After the hearing, the ALJ issued a written opinion explaining his decision.

(Tr. at 11–29). In issuing his decision, the ALJ followed the five-step evaluation process set out by the Social Security Administration. See 20 CFR 416.920(a). The steps are followed in order and, if it is determined that the claimant is or is not disabled at a particular step of the evaluation process, the ALJ will not proceed to the next step.

The first step requires the ALJ to determine whether the claimant is engaging in substantial gainful activity, which is defined as work involving significant physical or mental activities usually done for pay or profit. If a claimant is engaged

in substantial gainful activity, she is not disabled, and the inquiry stops. Otherwise, the ALJ will proceed to step two. In the present case, the ALJ found that Taylor did not engage in substantial gainful activity during the relevant time period. (Tr. at 13– 14). Accordingly, the ALJ moved on to the second step of the evaluation.

At step two, an ALJ is to determine whether the claimant has a medically determinable impairment that is “severe” or a combination of impairments that is “severe.” 20 C.F.R. 416.920(c). An impairment is severe if it “significantly limits

[a claimant’s] physical or mental ability to do basic work activities . . . .” Id. If a claimant does not have a severe impairment, she is not disabled, and the inquiry ends. If she does have a severe impairment, the ALJ will proceed to the third step. In the present case, the ALJ found that Taylor had the following severe impairments:

“obesity; degenerative disc disease; fibromyalgia; psoriatic arthritis; and psoriasis.” (Tr. at 14 (citing 20 CFR 404.1520(c))). At the third step, an ALJ determines whether the claimant’s impairments or

combination thereof are of a severity to meet or medically equal the criteria of an impairment listed in 20 CFR Part 404, Subpart P, Appendix I. If the claimant’s impairment or impairments meet or equal a listed impairment, then the claimant is

disabled, and the evaluation ends. Otherwise, the ALJ proceeds to the next step. In this case, the ALJ found that Taylor’s impairments did not meet or equal any of the listed criteria. (Tr. at 20). Specifically, the ALJ reviewed listings for musculoskeletal

disorders and mental disorders. (Id. (“I have considered all listings, but specifically listings 1.15, 1.18, and 12.06.”)). After reviewing the evidence, the ALJ concluded that there was no evidence of medical findings that were the same or equivalent to any of the listed impairments. (Id.). Therefore, the ALJ proceeded to step four.

Step four of the evaluation requires an ALJ to first determine the claimant’s residual functional capacity (“RFC”), and whether she has the RFC to perform the requirements of any past relevant work. 20 C.F.R. 416.920(f). The term “past

relevant work” means work performed within the last 15 years prior to the alleged date of onset. If a claimant has the RFC to perform past relevant work, she is not disabled, and the evaluation stops. Otherwise, the evaluation proceeds to the final step. In Taylor’s case, the ALJ found that she had the residual functional capacity

to perform a full range of sedentary work as defined in 20 CFR 404.1567(a) with specific limitations: After careful consideration of the entire record, I find that, through the date last insured, the claimant had the residual functional capacity to perform sedentary work as defined in 20 CFR 404.1567(a) except she could occasionally climb ramps or stairs. She could never climb ladders, ropes, or scaffolds. She could occasionally balance, stoop, kneel, crouch, or crawl. The claimant was capable of walking with the use of one cane with full use of the other upper extremity for fine or gross movements. She could occasionally be exposed to weather or humidity, extreme cold, extreme heat. She was limited to no exposure to excessive vibration. She could never be exposed to workplace hazards such as moving mechanical parts and high, exposed places. (Id.; see Tr. 20–27). Given this RFC, the ALJ determined that Taylor was able to perform her past relevant work as a telemarketer given that such work would not require Taylor to perform work-related activities precluded by her RFC. (Tr. at 27). This finding was based in part on testimony from a vocational expert who testified at Taylor’s hearing. Based on the findings above, the ALJ determined that Taylor was not disabled as defined by the Social Security Administration. (Tr. at 28). III. Standard of Review This Court must determine whether the Commissioner’s decision is supported by substantial evidence and whether the correct legal standards were applied.

Winschel v. Comm'r of Social Sec., 631 F.3d 1176, 1178 (11th Cir. 2011).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Andrew T. Wilson v. Jo Anne B. Barnhart
284 F.3d 1219 (Eleventh Circuit, 2002)
Bobby Dyer v. Jo Anne B. Barnhart
395 F.3d 1206 (Eleventh Circuit, 2005)
Christi L. Moore v. Jo Anne B. Barnhart
405 F.3d 1208 (Eleventh Circuit, 2005)
Winschel v. Commissioner of Social Security
631 F.3d 1176 (Eleventh Circuit, 2011)
Chambers v. Astrue
671 F. Supp. 2d 1253 (N.D. Alabama, 2009)
Horton v. Barnhart
469 F. Supp. 2d 1041 (N.D. Alabama, 2006)
Michelle Zuba-Ingram v. Commissioner of Social Security
600 F. App'x 650 (Eleventh Circuit, 2015)
Thomas Scott Henry v. Commissioner of Social Security
802 F.3d 1264 (Eleventh Circuit, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Taylor v. Social Security Administration, Commissioner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/taylor-v-social-security-administration-commissioner-alnd-2025.