Timothy Isaac Briggs v. Commissioner of Social Security

District Court, E.D. Tennessee·Decided August 18, 2026·No. 2:25-cv-00119·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TENNESSEE AT GREENEVILLE

TIMOTHY ISAAC BRIGGS, ) ) Plaintiff, ) ) v. ) ) No. 2:25-cv-119-MJD COMMISSIONER OF SOCIAL SECURITY, ) ) Defendant. )

MEMORANDUM AND ORDER

Plaintiff Timothy Isaac Briggs (“Plaintiff”) brought this action pursuant to 42 U.S.C. § 405(g) and 1383(c)(3), seeking judicial review of the final decision of the Commissioner of Social Security (the “Commissioner”) denying his disability insurance benefits (“DIB”) and supplemental Security Income Benefits (“SSI”) [Doc. 1]. Plaintiff filed a brief in support of his claims on January 22, 2026 [Doc. 17]. The Commissioner filed his response on June 11, 2026 [Doc. 24]. Plaintiff did not file a reply and the time for doing so has now passed. Therefore, this matter is ripe for review. For the reasons stated below, (1) Plaintiff’s request for relief [Doc. 1] will be DENIED, and (2) the Commissioner’s request that the administrative law judge’s (“ALJ”) final decision denying benefits be affirmed [Doc. 24] will be GRANTED. I. ADMINISTRATIVE PROCEEDINGS According to the administrative record [Doc. 9 (“Tr.”)], Plaintiff protectively filed a Title II application for DIB on August 17, 2023, alleging disability beginning January 1, 2013 (Tr. 205– 206, 216–222). Plaintiff also protectively filed a Title XVI application for SSI on August 17, 2023 (Tr. 205–15). Plaintiff’s claims were denied initially and on reconsideration at the agency level (Tr. 95–103; 107–113). Plaintiff requested a hearing before an ALJ (Tr. 119–20). The hearing was conducted in person on November 14, 2024, in Kingsport, Tennessee (Tr. 26). On November 27, 2024, the ALJ found Plaintiff had not been under a disability, as defined in the Social Security Act, at any time between his alleged onset of disability date (January 1, 2013) and the date of the ALJ’s decision (November 27, 2024) (Tr. 37). The ALJ found that

Plaintiff was not disabled for purposes of his DIB and SSI claims (Tr. 37). The Appeals Council denied Plaintiff’s request for review on June 11, 2025 (Tr. 12), making the ALJ’s decision the final decision of the Commissioner. Plaintiff timely filed the instant action on August 1, 2025 [Doc. 1]. II. FACTUAL BACKGROUND A. Education and Employment Background Plaintiff was born on July 31, 1998 (Tr. 207), making him 14 years old on the alleged onset of disability date, which is considered a “younger individual age 18–44.” 20 C.F.R. §§ 404.1563 and 416.963. He has at least a high school education and can communicate in English (Tr. 264). He has no past relevant work (Tr. 36).

B. Medical Records In his October 2023 Adult Disability Report, Plaintiff alleged disability due to Beckers Muscular Dystrophy (Tr. 263). In his subsequent Adult Disability Report, dated April 1, 2024, Plaintiff reported that there had been no change (for better or worse) in his physical condition (Tr. 307). Plaintiff also reported, however, that there had been a change in his daily activities due to his physical condition in that he was having “frequent falls” and was having to use a cane (Tr.

2 309). In his subsequent Adult Disability Report, dated May 29, 2024, Plaintiff’s representative1 reported that Plaintiff had a change in his physical or mental condition2 and stated as follows: Mr. Briggs has several severe disorders/conditions that continue to worsen and increase in severity. He has been diagnosed with Becker’s Muscular Dystrophy which has led to muscle weakness in his arms, neck, and lower body. Mr. Briggs has severe difficulty getting around. He is unable to walk without assistance. He is unable to sit or stand for long periods of time. His Becker’s muscular dystrophy has caused him severe, constant pain that makes it hard to move at all. He suffers from frequent falls and is unable to get up without assistance. Mr. Briggs also suffers from learning disabilities, making it hard to understand/comprehend complex tasks. He is unable to use a computer and has difficulties when speaking.

(Tr. 316). Plaintiff’s representative also reported that there had been a change in Plaintiff’s daily activities due to his physical or mental conditions, repeating the aforementioned paragraph for explanation (Tr. 319). While there is no need to summarize all the medical records herein, relevant records have been reviewed. C. Hearing Testimony At the hearing held on November 14, 2024 (the “Hearing”), Plaintiff and vocational expert Chelsea Brown (“VE”) testified. Plaintiff was represented by Attorney Michael Bock. The Court has carefully reviewed the transcript of the Hearing (Tr. 43–55). III. ELIGIBILITY AND THE ALJ’S FINDINGS A. Eligibility “The Social Security Act defines a disability as the ‘inability 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

1 Plaintiff’s appointed representative was Attorney Haley Morgan Henry (Tr. 114–117).

2 The date this change occurred was reported as January 1, 2013, the date of Plaintiff’s disability (Tr. 316). 3 of not less than 12 months.’” Schmiedebusch v. Comm’r of Soc. Sec., 536 F. App’x 637, 646 (6th Cir. 2013) (quoting 42 U.S.C. § 423(d)(1)(A)); see also Parks v. Soc. Sec. Admin., 413 F. App’x 856, 862 (6th Cir. 2011) (quoting 42 U.S.C. § 423(d)(1)(A)). A claimant is disabled “only if his physical or mental impairment or impairments are of such severity that he is not only unable to do his previous work, but cannot, considering his age, education, and work experience, engage in any

other kind of substantial gainful work which exists in the national economy.” Parks, 413 F. App’x at 862 (quoting 42 U.S.C. § 423(d)(2)(A)). The Social Security Administration (“SSA”) determines eligibility for disability benefits by following a five-step process: 1) If the claimant is doing substantial gainful activity, the claimant is not disabled.

2) If the claimant does not have a severe medically determinable physical or mental impairment—i.e., an impairment that significantly limits his or her physical or mental ability to do basic work activities—the claimant is not disabled.

3) If the claimant has a severe impairment(s) that meets or equals one of the listings in Appendix 1 to Subpart P of the regulations and meets the duration requirement, the claimant is disabled.

4) If the claimant’s impairment does not prevent him or her from doing his or her past relevant work, the claimant is not disabled.

5) If the claimant can make an adjustment to other work, the claimant is not disabled.

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Timothy Isaac Briggs v. Commissioner of Social Security, (E.D. Tenn. 2026).

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