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Hatter v. Colvin

United States District Court, N.D. Alabama, Southern Division

February 27, 2015

SHARON N. HATTER, Plaintiff,
v.
CAROLYN W. COLVIN, ACTING COMMISSIONER OF SOCIAL SECURITY ADMINISTRATION, [1] Defendant.

MEMORANDUM OPINION[2]

JOHN H. ENGLAND, III, Magistrate Judge.

Plaintiff Sharon N. Hatter ("Hatter") seeks review, pursuant to 42 U.S.C. § 405(g), § 205(g) of the Social Security Act, of a final decision of the Commissioner of the Social Security Administration ("Commissioner"), denying her application for widow's insurance benefits and Supplemental Security Income ("SSI"). (Doc. 1). Hatter timely pursued and exhausted her administrative remedies. This case is therefore ripe for review under 42 U.S.C. §§ 405(g), 1383(c)(3). The undersigned has carefully considered the record and, for the reasons stated below, the undersigned recommends the Commissioner's decision be AFFIRMED.

I. Factual and Procedural History

Hatter was a fifty-two old female at the time of the Administrative Law Judge's ("ALJ") decision. (Tr. 8, 53, 159, 176, 183). Hatter has at least a high school education and past relevant work as a mailroom clerk, general clerk, and housekeeper/cleaner. (Tr. 54-55, 73, 188-89, 194-97, 226).

Hatter filed her applications for widow's insurance benefits and SSI on October 4, 2010, alleging an onset date of August 4, 2010. (Tr. 11, 159-65, 176-82). The Commissioner initially denied Hatter's application, and Hatter requested a hearing before an ALJ. (Tr. 92-104). After a hearing, the ALJ denied Hatter's claim on January 10, 2013. (Tr. 8-31). Hatter sought review by the Appeals Council, but it declined her request on July 31, 2013. (Tr. 1-6). On that date, the ALJ's decision became the final decision of the Commissioner. On September 30, 2013, Hatter initiated this action. ( See doc. 1).

II. Standard of Review[3]

The court's review of the Commissioner's decision is narrowly circumscribed. The function of this 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.

This Court must uphold factual findings 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 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.[4] The Regulations define "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). The Commissioner must determine in sequence:

(1) whether the claimant is currently employed;
(2) whether the claimant has a severe impairment;
(3) whether the claimant's impairment meets or equals an impairment listed by ...

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