United States District Court, N.D. Alabama, Middle Division
K. KALLON UNITED STATES DISTRICT JUDGE
Nicole Freeman brings this action on behalf of her minor
child, I.F., pursuant to Section 405(g) of the Social
Security Act, 42 U.S.C. § 405(g), seeking review of the
Administrative Law Judge's (“ALJ's”)
denial of disability insurance benefits, which has become the
final decision of the Commissioner of the Social Security
Administration (“SSA”). For the reasons explained
below, the court finds that the ALJ applied the correct legal
standards and that his decision is supported by substantial
evidence. Accordingly, the decision is due be affirmed.
filed an application for Disability Insurance Benefits
(“DIB”) on behalf of her minor daughter, I.F.,
asserting that I.F. suffered from a disability beginning on
August 31, 2009 due to autism. R. 244, 258. On April 6, 2011,
the SSA found I.F. to be disabled as defined by the Act
beginning January 19, 2011, when I.F. was three years old,
and awarded her benefits. R. 45. As required by statute, the
SSA conducted a continuing disability review and determined
that I.F. was no longer disabled for purposes of the Act as
of January 1, 2015, when I.F. was seven years old. R. 45,
86-87, 90. Freeman requested reconsideration, and a
disability hearing officer upheld the finding that I.F. was
no longer disabled. R. 45, 89, 95-98, 105-13. Subsequently,
Freeman requested a hearing before an ALJ, who also found
that I.F.'s disability ended as of January 1, 2015 and
that I.F. has not been disabled since that date. R. 45, 135.
The SSA Appeals Council denied Freeman's request for
review, rendering the ALJ's decision the final decision
of the Commissioner. R. 1. Having exhausted her
administrative remedies, Freeman filed this petition for
review pursuant to 42 U.S.C. §§ 1383(c)(3) and
405(g). Doc. 1.
STANDARD OF REVIEW
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)).
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.'” Id.
(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.
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.
STATUTORY AND REGULATORY FRAMEWORK
individual applying for DIB bears the burden of proving that
she is disabled. Moore v. Barnhart, 405 F.3d 1208
(11th Cir. 2011) (citation omitted). To qualify, 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) and 416(i)(I)(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).
claimants under age 18, determination of disability under the
Act requires a three-step analysis. Specifically, the
Commissioner must determine in sequence:
(1) whether the child is working;
(2) whether the child has a severe impairment or combination
of impairments; and
(3) whether the child's impairment or combination of
impairments meets, medically equals, or functionally equals
the severity of an impairment in the Listing of Impairments.
Parks ex rel. D.P. v. Comm'r, Soc. Sec. Admin.,
783 F.3d 847, 850 (11th Cir. 2015) (citing 20 C.F.R. §
416.924(a)). A child's impairment “medically
equals' the limitations in a listed impairment “if
the child's limitations ‘are at least of equal
medical significance to those of [the] listed
impairment.'” Shinn ex rel. Shinn v. Comm'r
of Soc. Sec., 391 F.3d 1276, 1279 (11th Cir. 2004)
(quoting 20 C.F.R. § 416.926(a)(2)). To determine
whether a child's impairment or combination of
impairments “functionally equals” a listed
impairment, the ALJ must assess the degree to which the
impairments limits the child's activities across the
following six domains:
(1) acquiring and using information;
(2) attending and completing ...