United States District Court, N.D. Alabama, Middle Division
JOHN E. OTT, Chief Magistrate Judge.
Plaintiff Tracy Torris Hunt brings this action pursuant to 42 U.S.C. § 405(g), seeking review of the final decision of the Acting Commissioner of Social Security ("Commissioner") denying his applications for disability insurance benefits and supplemental security income ("SSI"). (Doc. 1). He also requests that the court remand this matter to the Administrative Law Judge ("ALJ") pursuant to sentences four and six of 42 U.S.C. § 405(g). The case has been assigned to the undersigned United States Magistrate Judge pursuant to this court's general order of reference dated January 14, 2013. Upon review of the record and the relevant law, the undersigned finds that the Commissioner's decision is due to be affirmed and that Hunt's requests for a remand is due to be denied.
I. PROCEDURAL HISTORY
Hunt filed applications for disability insurance benefits and SSI in June 2010, alleging disability beginning March 27, 2009, due to back problems and depression. (R. 176). His claims were denied initially. He then requested a hearing before an Administrative Law Judge ("ALJ"), which was held on April 10, 2012. (R. 37-79). Hunt was represented by counsel at the hearing. (R. 10). On June 19, 2012, the ALJ issued his decision finding that Hunt was not entitled to any disability benefits. (R. 10).
Hunt requested that the Appeals Council review the ALJ's decision. The Appeals Council denied his request for review on September 10, 2013. (R. 1). On that date, the ALJ's decision became the final decision of the Commissioner. Hunt then filed this action for judicial review under 42 U.S.C. § 405(g), asserting that the findings of the Commissioner were not based upon substantial evidence and were not determined by proper legal standards. (Doc. 1).
II. STANDARD OF REVIEW
The court's review of the Commissioner's decision is narrowly circumscribed. The function of the court is to determine whether the decision of the Commissioner is supported by substantial evidence and whether proper legal standards were applied. Richardson v. Perales, 402 U.S. 389, 390, 91 S.Ct. 1420, 1422 (1971); Wilson v. Barnhart, 284 F.3d 1219, 1221 (11th Cir. 2002). This court must "scrutinize the record as a whole to determine if the decision reached is reasonable and supported by substantial evidence." Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983). Substantial evidence is "such relevant evidence as a reasonable person would accept as adequate to support a conclusion." Id. It is "more than a scintilla, but less than a preponderance." Id.
The court must uphold factual findings that are supported by substantial evidence. However, it reviews the ALJ's legal conclusions de novo because no presumption of validity attaches to the ALJ's determination of the proper legal standards to be applied. Davis v. Shalala, 985 F.2d 528, 531 (11th Cir. 1993). If the court finds an error in the ALJ's application of the law, or if the ALJ fails to provide the court with sufficient reasoning for determining that the proper legal analysis has been conducted, it must reverse the ALJ's decision. Cornelius v. Sullivan, 936 F.2d 1143, 1145-46 (11th Cir. 1991).
III. STATUTORY AND REGULATORY FRAMEWORK
To qualify for disability benefits and establish his or her entitlement for a period of disability, a claimant must be disabled as defined by the Social Security Act and the Regulations promulgated thereunder. The Regulations define being "disabled" as "the inability to do 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 twelve (12) months." 20 C.F.R. § 404.1505(a). To establish entitlement to disability benefits, a claimant must provide evidence of a "physical or mental impairment" which "must result from anatomical, physiological, or psychological abnormalities which can be shown by medically acceptable clinical and laboratory diagnostic techniques." 20 C.F.R. § 404.1508.
The Regulations provide a five-step process for determining whether a claimant is disabled. 20 C.F.R. §§ 404.1520(a)(4)(i-v) and 416.920(a)(4)(i-v). The Commissioner must determine in sequence:
(1) Is the claimant presently unemployed;
(2) Is the claimant's impairment severe;
(3) Does the claimant's impairment meet or equal one of the specific impairments set forth in 20 C.F.R. pt. 404, subpt. P, app. 1 [the "Listings"];
(4) Is the claimant unable to perform his or her former occupation;
(5) Is the claimant unable to perform any other work ...