Williams v. Social Security Administration, Commissioner

CourtDistrict Court, N.D. Alabama
DecidedFebruary 7, 2025
Docket2:24-cv-00555
StatusUnknown

This text of Williams v. Social Security Administration, Commissioner (Williams 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
Williams v. Social Security Administration, Commissioner, (N.D. Ala. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF ALABAMA SOUTHERN DIVISION CATHY M. WILLIAMS, ) ) Claimant, ) ) vs. ) Civil Action No. 2:24-cv-555-CLS ) MICHELLE KING, Acting ) Commissioner of Social Security, ) ) Defendant. ) MEMORANDUM OPINION Cathy M. Williams commenced this suit pursuant to 42 U.S.C. § 405(g), seeking judicial review of a final adverse decision of the Commissioner of Social Security, affirming the decision of an Administrative Law Judge (“ALJ”) and, thereby, denying her claim for a period of disability and disability insurance benefits. For the reasons stated herein, the court finds that the Commissioner’s ruling is due to be reversed, and remanded to the Commissioner with an instruction to award benefits. I. STANDARDS OF REVIEW The court’s role in reviewing claims brought under the Social Security Act is a narrow one. The scope of review is limited to determining whether there is

substantial evidence in the record as a whole to support the findings of the Commissioner, and, whether correct legal standards were applied. See Lamb v. Bowen, 847 F.2d 698, 701 (11th Cir. 1988); Tieniber v. Heckler, 720 F.2d 1251, 1253

(11th Cir. 1983). The court may not “decide the facts anew, reweigh the evidence, or substitute [its] judgment for that of the Commissioner.” Winschel v. Commissioner of Social Security, 631 F.3d 1176, 1178 (11th Cir. 2011) (alteration supplied).

II. CLAIMANT’S CONTENTIONS The claimant, Cathy M. Williams, contends that the Commissioner’s decision is neither supported by substantial evidence, nor in accordance with applicable legal

standards. Specifically, she asserts that: (1) the ALJ did not comply with the mandate of the Appeals Council to employ a psychological expert; (2) the ALJ failed to evaluate properly the opinions of Marilyn Lachman, M.D.; (3) the ALJ’s decision is

not supported by substantial evidence; and (4) remand for an award of benefits is warranted.1 Upon review of the record, the court concludes that those contentions have merit.

III. PROCEDURAL BACKGROUND This claim has remained unresolved for more than a decade. Claimant initially filed an application for a period of disability and disability insurance benefits on May

1 Doc. no. 17 (Plaintiff’s Opening Brief). 2 15, 2014.2 Following an administrative hearing, the ALJ issued an unfavorable decision on August 2, 2016.3 Claimant requested review by the Appeals Council, but

review was denied on June 26, 2017.4 Claimant then appealed the decision to this court. On May 25, 2018, upon the motion of the Commissioner, the court reversed the Commissioner’s decision and remanded the case pursuant to sentence four of 42

U.S.C. § 405(g), for additional proceedings. See Williams v. Commissioner of Social Security, Civil Action No. 4:17-cv-1467-JHE (N.D. Ala. May 25, 2018).5 A new hearing was conducted, after which, on August 6, 2019, the ALJ issued another

unfavorable decision.6 Claimant sought review of that decision by the Appeals Council, but, on May 15, 2020, the Appeals Council declined to assume jurisdiction.7 Claimant filed a civil

action, and this court affirmed the ALJ’s decision on May 26, 2021.8 Claimant appealed to the Eleventh Circuit. The Commissioner’s motion to remand the case to the district court was granted by the Circuit on August 25, 2021.9 This court then

2 R. 96. 3 R. 23-37. 4 R. 1-4. 5 The order remanding the case is not contained in the record. 6 R. 1262-88. 7 R. 1252-55. 8 R. 2014, 2016-28. 9 R. 2030. 3 remanded the case to the Commissioner on August 30, 2021.10 The Appeals Council vacated the final decision of the Commissioner on

November 16, 2021. In doing so, the Appeals Council observed that: The hearing decision indicates that the claimant has the residual functional capacity (RFC) to perform a reduced range of medium work, but the decision does not contain sufficient rationale with specific references to evidence of record in support of the assessed limitations. It is unclear how the ALJ determined the functional limitations resulting from the claimant’s mental and physical impairments. The only opinion that the ALJ credits is from the State agency medical consultant, Robert Estock, M.D., who found there was insufficient evidence in the record to formulate an RFC for the period at issue. The Appeals Council notes, however, that a significant amount of evidence was offered into the record after Dr. Estock reviewed the record that may be used as the basis to formulate the claimant’s RFC. Furthermore, the ALJ gave little weight to all the opinions from medical providers related to the claimant’s mental condition. While an ALJ does not have to rely on opinion evidence to formulate the limitations in the RFC, he or she does have to provide a narrative discussion with cites to evidence in the record for how the restrictions were derived pursuant to Social Security Ruling 96-8p. The hearing decision does not contain such a narrative discussion for each of the physical and mental limitations, and therefore, it is unclear if more or less restrictive limitations are appropriate. Thus, further consideration of the claimant’s RFC is necessary, with medical expert and psychological or psychiatric expert evidence. R. 2035 (internal citations omitted, emphasis supplied). The ALJ was instructed by the Appeals Council to: ! Obtain evidence from a medical expert and psychological or psychiatric expert related to the nature and severity of and functional limitations resulting from the claimant’s physical and 10 R. 2032. 4 mental impairments (20 CFR 404.1513a(b)(2)). ! Give further consideration to the claimant’s maximum RFC and provide appropriate rationale with specific references to evidence of record in support of the assessed limitations (20 CFR 404.1545 and Social Security Rulings 85-16 and 96-8p). ! If warranted by the expanded record, obtain supplemental evidence from a vocational expert to clarify the effect of the assessed limitations on the claimant’s occupational base (Social Security Ruling 83-14). The hypothetical questions should reflect the specific capacity/limitations established by the record as a whole. The ALJ will ask the vocational expert to identify examples of appropriate jobs and to state the incidence of such jobs in the national economy (20 CFR 404.1566). Further, before relying on the vocational expert evidence, the ALJ will identify and resolve any conflicts between the occupational evidence provided by the vocational expert and information in the Dictionary of Occupational Titles (DOT) and its companion publication, the Selected Characteristics of Occupations (Social Security Ruling 00-4p). R. 2036. Yet another administrative hearing was conducted by a different ALJ on April 12, 2022.11 On the date of that hearing, however, the new ALJ had not obtained the medical and psychological evidence required by the Appeals Council’s order of remand.12 Notwithstanding, the ALJ heard claimant’s testimony on her claim and posed questions based upon hypothetical work limitations to a vocational expert.13 11 R. 1923-46. 12 See R. 1928. 13 R. 1943-44.

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Williams v. Social Security Administration, Commissioner, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-social-security-administration-commissioner-alnd-2025.