United States District Court, N.D. Alabama, Middle Division
MEMORANDUM OPINION
ABDUL
K. KALLON, UNITED STATES DISTRICT JUDGE
Brian
Eugene Jacobs 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 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
Jacobs
worked as a forklift operator, press operator, and assembly
line worker until he stopped working in 2014 at age 46 due to
his alleged disability. R. 420-21, 432, 435. Thereafter,
Jacobs filed applications for disability benefits, asserting
initially that he suffered from a disability beginning
January 1, 2014, but amending it later to December 26, 2014,
due to a heart condition, blood clots, and a history of a
gunshot wound. R. 12, 101-02, 374, 378, 420. After the SSA
denied Jacobs' application, Jacobs requested a formal
hearing before an ALJ. R. 260-62. The ALJ held two
administrative hearings to allow Jacobs to submit additional
medical records that he had not submitted before the first
hearing. See R. 50, 97, 103. Ultimately, the ALJ
entered a decision against Jacobs. R. 9-27. The SSA Appeals
Council summarily affirmed the ALJ's decision denying
disability benefits, rendering the ALJ's decision the
final decision of the Commissioner. R. 1. Having exhausted
his administrative remedies, Jacobs filed this action
pursuant to 42 U.S.C. §§ 1383(c)(3) and 405(g).
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 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 requires a
five-step analysis. 20 C.F.R. § 404.1520(a).
Specifically, the ALJ 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
work; and
(5) whether the claimant is unable to perform any work in the
national economy.
See McDaniel v. Bowen, 800 F.2d 1026, 1030 (11th
Cir. 1986). “An affirmative answer to any of the above
questions leads either to the next question, or, on steps
three and five, to a finding of disability. A negative answer
to any question, other than step three, leads to a
determination of ‘not disabled.'”
Id. (citing 20 C.F.R. § 416.920(a)-(f)).
“Once [a] finding is made that a claimant cannot return
to prior work the burden of proof shifts to the Secretary to
show other work the claimant can do.” Foote v.
Chater, 67 F.3d 1553, 1559 (11th Cir. 1995). However,
the claimant ultimately bears the burden of proving that she
is disabled, and, “consequently he is responsible for
producing evidence in support of his claim.” See,
e.g., Ellison v. Barnhart, 355 F.3d 1272, 1276
(11th Cir. 2003) (citing 20 C.F.R. § 416.945(a), (c)).
The Act
precludes an award of benefits when drug or alcohol abuse is
a contributing factor material to the finding of disability.
See 42 U.S.C. § 423(d)(2)(C); 20 C.F.R. §
404.1525. Thus, if a claimant is found disabled and medical
evidence of substance abuse exists, the ALJ must determine
whether the substance abuse is a contributing factor to the
finding of disability. 20 C.F.R. § 404.1535(a). To do
so, the ALJ must evaluate which of the claimant's
physical and mental limitations would remain if he stopped
using drugs or alcohol and then decide whether any of those
remaining limitations would be disabling. Id. at
§ 404.1535(b)(2).
IV.
THE ...