United States District Court, N.D. Alabama, Jasper Division
KARON OWEN BOWDRE, Chief District Judge.
On February 24, 2011, the claimant, Patsy Dobson, applied for disability insured benefits under Title II and supplemental security income under Title XVI of the Social Security Act. (R. 116-24, 125-28). The claimant initially alleged that she became disabled on October 9, 2008. (R. 138). The Commissioner denied the claimant's applications. (R. 65-66). The claimant filed a timely request for a hearing before an Administrative Law Judge. (R. 74). At the June 27, 2012 hearing, the claimant amended her alleged disability onset date to July 20, 2010. (R. 26).
On July 27, 2012, the ALJ issued a decision denying the claimant's applications, finding that the claimant was not disabled as defined by the Social Security Act and was, therefore, ineligible for social security benefits. (R. 19). The Appeals Council denied the claimant's request for a review of the hearing decision on June 13, 2013. (R. 1). Consequently, the ALJ's decision became the final decision of the Commissioner of the Social Security Administration. (R. 1). The claimant has exhausted her administrative remedies, and this court has jurisdiction pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3). For the reasons stated below, the court REVERSES AND REMANDS the decision of the Commissioner.
II. ISSUE PRESENTED
The claimant presents the following issue for review: whether the ALJ properly rejected the opinions of the claimant's treating physicians based on
(a) inconsistencies in her medical records from the Florida and Alabama facilities; and
(b) the claimant's non-compliance with treatment in Alabama.
III. STANDARD OF REVIEW
The standard for reviewing the Commissioner's decision is limited. This court must affirm the Commissioner's decision if the Commissioner applied the correct legal standards and if his factual conclusions are supported by substantial evidence. See 42 U.S.C. § 405(g); Graham v. Apfel, 129 F.3d 1420, 1422 (11th Cir. 1997); Walker v. Bowen, 826 F.2d 996, 999 (11th Cir. 1987).
"No... presumption of validity attaches to the [Commissioner's] legal conclusions, including determination of the proper standards to be applied in evaluating claims." Walker, 826 F.2d at 999. This court does not review the Commissioner's factual determinations de novo. The court will affirm those factual determinations that are supported by substantial evidence. "Substantial evidence" is "more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion." Richardson v. Perales, 402 U.S. 389, 402 (1971).
The court must keep in mind that opinions such as whether a claimant is disabled, the nature and extent of a claimant's residual functional capacity, and the application of vocational factors "are not medical opinions, ... but are, instead, opinions on issues reserved to the Commissioner because they are administrative findings that are dispositive of a case; i.e., that would direct the determination or decision of disability." 20 C.F.R. §§ 404.1527(d), 416.927(d). Whether the claimant meets the listing and is qualified for Social Security disability benefits is a question reserved for the ALJ, and the court "may not decide facts anew, reweigh the evidence, or substitute [its] judgment for that of the Commissioner." Dyer v. Barnhart, 395 F.3d 1206, 1210 (11th Cir. 2005). Thus, even if the court were to disagree with the ALJ about the significance of certain facts, the court has no power to reverse that finding as long as substantial evidence in the record supports it.
The court must "scrutinize the record in its entirety to determine the reasonableness of the [Commissioner]'s factual findings." Walker, 826 F.2d at 999. A reviewing court must not only look to those parts of the record that support the decision of the ALJ, but also must view the record in its entirety and take account of evidence that detracts from the evidence relied on by the ALJ. Hillsman v. Bowen, 804 F.2d 1179, 1180 (11th Cir. 1986). A decision is not based on substantial evidence that focuses on one aspect of the evidence while disregarding other contrary evidence. McCruter v. Bowen, 791 F.2d 1544, 1548 (11th Cir. 1986).
IV. LEGAL STANDARD
Under 42 U.S.C. § 423(d)(1)(A), a person is entitled to disability benefits when the person is unable 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 of not less than 12 months...." 42 U.S.C. § 423(d)(1)(A). To make this determination the Commissioner employs a five-step, sequential evaluation process:
(1) Is the person presently unemployed?
(2) Is the person's impairment severe?
(3) Does the person's impairment meet or equal one of the specific impairments set forth in 20 C.F.R. ...