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Weeks v. Saul

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

December 4, 2019

WANDA WEEKS, Plaintiff,
v.
ANDREW SAUL,[1] Commissioner of Social Security, Defendant.

          MEMORANDUM OPINION

          ABDUL K. KALLON UNITED STATES DISTRICT JUDGE.

         Wanda Weeks brings this action 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”) denial of disability insurance benefits and supplemental security income, 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 her decision is supported by substantial evidence. Therefore, the court affirms the decision denying benefits.

         I. PROCEDURAL HISTORY

         Weeks worked as an assembly press operator, inspector, department manager, cashier/checker, wire worker, line worker, and administrative clerk for many years until she stopped working at age 54 due to her alleged disability. R. 24, 171, 178, 207-08. Thereafter, Weeks filed applications for disability insurance benefits and supplemental security income, alleging that she suffered from a disability, beginning October 3, 2015, [2] due to osteoarthritis, fibromyalgia, nerve damage, depression, degenerative disc disease in neck, sleep problems, thyroid disease, and carpal tunnel syndrome. R. 71, 200, 207. After the SSA denied her applications, R. 95, 100, Weeks requested a hearing, R. 105. Subsequently, an ALJ entered a decision finding that Weeks was not disabled. R. 15-25. The SSA Appeals Council denied review, rendering the ALJ's decision the final decision of the Commissioner. R.1. Having exhausted her administrative remedies, Weeks timely filed this petition for review pursuant to 42 U.S.C. §§ 1383(c)(3) and 405(g). Doc. 1.

         II. STANDARD OF REVIEW

         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); 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.” Id. at § 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 or combination of impairments 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 ...

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