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Douglass v. Commissioner, Social Security Administration

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

October 16, 2017

JEREMY JERWAYNE DOUGLASS, Plaintiff,
v.
COMMISSIONER, SOCIAL SECURITY ADMINSTRATION, Defendant.

          MEMORANDUM OPINION

          ABDUL K. KALLON, UNITED STATES DISTRICT JUDGE

         Jeremy Jerwayne Douglass brings this action pursuant to 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 standard and that her 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

         The administrative proceedings in this case stretch back to December 18, 2008, when an application for Supplemental Security Income (SSI) benefits was filed on Douglass' behalf. Doc. 10 at 1-2.[1] The application alleged that Douglass became disabled on November 12, 2008 because of multiple mental and physical impairments suffered as a result of a serious car accident. Id.; (R. 438). After review, the claim was allowed based on Douglass' history of chronic asthma and a closed head injury he received in the accident. Doc. 10 at 2-3.

         Douglass turned 18 in August 2010, and approximately a year later he was informed that, as an adult, he was no longer considered disabled. Doc. 10 at 2; (R. 126-27). Accordingly, his benefits were scheduled to terminate in October 2011, and on August 31, 2011 Douglass requested reconsideration of that decision. Doc. 10 at 2. The initial reconsideration process culminated in a hearing before an ALJ on July 25, 2013. Id. Douglass was unrepresented at that hearing, which was continued so that he could obtain representation. (R. 116). Finally, on January 17, 2014, a full hearing was conducted, after which the ALJ entered a decision extending disability benefits through May 1, 2012 to account for a lengthy period of hospitalization Douglass underwent after developing empyema in his left lung. (R. 134, 136, 143-44). From that point forward, however, the ALJ determined that Douglass was no longer disabled. (R. 144).

         Douglass appealed, and on August 24, 2015 the SSA Appeals Council (AC) reversed the ALJ, finding that she had not adequately addressed Douglass' claim of mental impairment and that she had insufficiently considered the non-examining medical source opinions when determining Douglass' Residual Functional Capacity (RFC). (R. 150, 152-54). Pursuant to this conclusion, the AC remanded the case to the ALJ for reevaluation. (R. 150, 154).

         Following another hearing, the ALJ issued a second decision on April 7, 2016. Doc. 11 at 2. The ALJ again denied Douglass' claim finding that his RFC allowed for a variety of light work following May 1, 2012, and that accordingly Douglass was not disabled after that date. Doc. 10 at 4. Douglass appealed the ruling, and the AC issued a form denial on September 7, 2016. Id. Having exhausted his administrative remedies, Douglass filed this action pursuant to 42 U.S.C. § 1383(c)(3) and 42 U.S.C. § 405(g) on November 11, 2016. Docs. 1at 1; 11 at 2.

         II. Standard of Review

         The only issues before this court are whether the record contains substantial evidence to sustain the ALJ's decision, see 42 U.S.C. § 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, 701 (11th Cir. 1988); Chester v. Bowen, 792 F.2d 129, 131 (11th Cir. 1986). Title 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.'” Id. (quoting 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). If supported by substantial evidence, the court must affirm the Commissioner's factual findings even if the preponderance of the evidence is against those findings. See Id. While judicial review of the ALJ's findings is limited in scope, it “does not yield automatic affirmance.” Lamb, 847 F.2d at 701.

         In contrast to the deferential review accorded the Commissioner's factual findings, “conclusions of law, including applicable review standards, are not presumed valid” and are subject to de novo review. Martin, 894 F.2d at 1529. The Commissioner's failure to “apply the correct legal standards or to provide the reviewing court with sufficient basis for a determination that proper legal principles have been followed” requires reversal. Id.

         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); 42 U.S.C. § 416(i)(1). 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 Social Security Act proceeds via a required five step analysis. 20 C.F.R. § 404.1520(a). ...


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