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