United States District Court, N.D. Alabama, Eastern Division
SHARON LOVELACE BLACKBURN, District Judge.
On April 16, 2002, the claimant, Brandi Melissa Little, applied for disability insurance benefits under Title II of the Social Security Act. (R. 72.) The Commissioner denied the claim both initially and on reconsideration. (R. 72-83, 91-95.) The claimant filed a timely request before an Administrative Law Judge ("ALJ"), and the ALJ held a hearing on January 7, 2013. (R. 30.)
In a decision dated March 6, 2013, the ALJ found that the claimant was not disabled as defined by the Social Security Act. (R. 11.) On June 18, 2013, the Appeals Council denied the claimant's request for review. Consequently, the ALJ's decision became the final decision of the Commissioner of the Social Security Administration ("Commissioner"). (R. 1-4.) The claimant has exhausted her administrative remedies and the decision of the Commissioner is ripe for review pursuant to 42 U.S.C. § 405(g).
Ms. Little was 32 years old at the time of the ALJ's decision, and she has a college degree. (R. 41.) Her past work experience was as a sales clerk, a production assembler, an inventory crew manager, and a fuel truck driver in the military. (R. 66-67.) Ms. Little alleges disability commencing on December 1, 2009, due to post traumatic stress disorder ("PTSD") with agoraphobia, depression, and a mild traumatic brain injury ("TBI"). (R. 13.)
II. STANDARD OF REVIEW
In reviewing claims brought under the Social Security Act, this court "is limited to an inquiry into whether there is substantial evidence to support the findings of the Commissioner, and whether the correct legal standards were applied." Wilson v. Barnhart, 284 F.3d 1219, 1221 (11th Cir. 2002); see also Lamb v. Bowen, 847 F.2d 698, 701 (11th Cir. 1988). The court gives deference to factual findings and reviews questions of law de novo. Cornelius v. Sullivan, 936 F.2d 1143, 1145 (11th Cir. 1991). The court "may not decide the facts anew, reweigh the evidence, or substitute [its] judgment for that of the [Commissioner], rather [it] must scrutinize the record as a whole to determine if the decision reached is reasonable and supported by substantial evidence." Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990) (quoting Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983)) (internal quotations and other citation omitted). "The Commissioner's factual findings are conclusive if supported by substantial evidence." Wilson, 284 F.3d at 1221 (citing Martin, 894 F.2d at 1529; Allen v. Bowen, 816 F.2d 600, 602 (11th Cir. 1987)). "Substantial evidence" is "more than a scintilla and is such relevant evidence as a reasonable person would accept as adequate to support a conclusion." Winschel v. Comm'r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011) (internal quotations and citations omitted)
The court reviews the Commissioner's conclusions of law de novo. Cornelius, 936 F.2d at 1145. "No... presumption of validity attaches to the [Commissioner's] conclusions of law." Wiggins v. Schweiker, 679 F.2d 1387, 1389 (11th Cir. 1982).
A. THE FIVE-STEP EVALUATION
When evaluating the disability of individuals over the age of 18, the regulations require the Commissioner to follow a five-step sequential evaluation to determine whether a claimant is eligible for a period of disability. See 20 C.F.R. §§ 404.1520, 416.920; Bowen v. City of New York, 476 U.S. 467, 470 (1986); see also Doughty v. Apfel, 245 F.3d 1274, 1278 (11th Cir. 2001). "[A]n individual shall be considered to be disabled for purposes of [determining eligibility for DIB and SSI benefits] if [she] 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 twelve months." 42 U.S.C. § 1382c(a)(3)(C)(1); see also 42 U.S.C. § 416(i)(1); 42 U.S.C. § 423(d)(1)(A). The specific steps in the evaluation are as follows:
1. Substantial Gainful Employment
First, the Commissioner must determine whether the claimant is engaged in "substantial gainful activity." Bowen v. Yuckert, 482 U.S. 137, 137 (1987). If the claimant is working and that work is substantial gainful activity, the Commissioner will find that the claimant is not disabled, regardless of the claimant's medical condition or her age, education, and work experience. 20 C.F.R. § 404.1520(b); 20 C.F.R. § 416.920(b). "Under the first step, the claimant has the burden to show that she is not currently engaged in substantial gainful activity." Reynolds-Buckley v. Commissioner of Social Sec., 457 F.Appx. 862, 863 (11th Cir. 2012).
The ALJ found that the claimant met the insured status requirements of the Social Security Act during the period from her alleged onset date of December 1, 2009, through her date last insured of June 30, 2012. (R. 13.) He also determined that she had ...