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Pruitt v. Social Security Administration, Commissioner

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

April 20, 2017

BRICE A. PRUITT, Plaintiff,
v.
SOCIAL SECURITY ADMINISTRATION, COMMISSIONER, Defendant.

          MEMORANDUM OPINION

          ABDUL K. KALLON UNITED STATES DISTRICT JUDGE.

         Brice A. Pruitt brings this action pursuant to Section 205(g) of the Social Security Act (“the Act”), 42 U.S.C. § 405(g), seeking review of the final adverse decision of the Commissioner of the Social Security Administration (“SSA”). This court finds that the Administrative Law Judge (“ALJ”) applied the correct legal standards and that his decision - which has become the decision of the Commissioner - is supported by substantial evidence. Therefore, the court AFFIRMS the decision denying benefits.

         I. PROCEDURAL HISTORY

         Pruitt protectively filed his application for Title XVI Supplemental Security Income on October 27, 2009, alleging a disability onset date of October 1, 2004 due to human immunodeficiency virus, major depression, and right hip and knee problems. (R. 33, 308). After the SSA denied his application, Pruitt requested a hearing before an ALJ. (R. 174-83, 189-92). The ALJ subsequently denied Pruitt's claim. (R. 156, 164). The Appeals Council granted Pruitt's request for review, and remanded the case to a different ALJ for further consideration. (R. 169-73). After the second ALJ denied Pruitt's application in April 2013, (R. 61), the Appeals Council denied review, (R. 7-11), rendering the ALJ's opinion the final decision of the Commissioner. Pruitt sought review by filing a civil action in federal district court and, pursuant to a voluntary remand motion by the Commissioner, Judge C. Lynwood Smith, Jr. of this court remanded for further proceedings. Relevant here, Judge Smith directed the ALJ to “clarify the limits of [Pruitt's] ability to interact with supervisors, and [to] obtain supplemental testimony from a vocational expert to clarify the effect of the assessed limitations on [Pruitt's] occupational base.” (R. 909). On remand, Pruitt had a hearing before a third ALJ, after which the ALJ issued a May 2016 decision denying benefits. (R. 830-57). Pruitt did not seek review by the Appeals Council, and the ALJ's decision became the final decision of the Commissioner. (R. 831). Pruitt then filed this action pursuant to § 405(g) on September 1, 2016. Doc. 1.

         II. STANDARD OF REVIEW

         The only issues before this court are whether the record contains substantial evidence to sustain the ALJ's decision, see § 405(g); Walden v. Schweiker, 672 F.2d 835, 838 (11th Cir. 1982), and whether the ALJ applied the correct legal standards, see Lamb v. Bowen, 847 F.2d 698, 791 (11th Cir. 1988); Chester v. Bowen, 792 F.2d 129, 131 (11th Cir. 1986). 42 U.S.C. §§ 405(g) and 1383(c) mandate that the Commissioner's “factual findings are conclusive if supported by ‘substantial evidence.'” Martin v. Sullivan, 894 F.2d 1520, 1529 (11th Cir. 1990). The district court may not reconsider the facts, reevaluate the evidence, or substitute its judgment for that of the Commissioner; instead, it must review the final decision as a whole and determine if the decision is “reasonable and supported by substantial evidence.” See Id. (citing Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983)).

         Substantial evidence falls somewhere between a scintilla and a preponderance of evidence; “[i]t is such relevant evidence as a reasonable person would accept as adequate to support a conclusion.” Martin, 894 F.2d at 1529 (quoting Bloodsworth, 703 F.2d at 1239) (other citations omitted). If supported by substantial evidence, the court must affirm the Commissioner's factual findings even if the preponderance of the evidence is against the Commissioner's findings. See Martin, 894 F.2d at 1529. While the court acknowledges that judicial review of the ALJ's findings is limited in scope, it notes that the review “does not yield automatic affirmance.” Lamb, 847 F.2d at 701.

         III. STATUTORY AND REGULATORY FRAMEWORK

         To qualify for disability benefits, a claimant must show “the inability 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. §§ 423(d)(1)(A), 416(i)(1)(A). A physical or mental impairment is “an impairment that results from anatomical, physiological, or psychological abnormalities which are demonstrated by medically acceptable clinical and laboratory diagnostic techniques.” 42 U.S.C. § 423(d)(3).

         Determination of disability under the Act requires a five-step analysis. 20 C.F.R. §§ 404.1520(a)-(f). Specifically, the Commissioner must determine, in sequence:

(1) whether the claimant is currently unemployed;
(2) whether the claimant has a severe impairment;
(3) whether the impairment meets or equals one listed by the Secretary;
(4) whether the claimant is unable to perform his or her past ...

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