United States District Court, N.D. Alabama, Southern Division
K. KALLON UNITED STATES DISTRICT JUDGE.
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.
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,  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.
STANDARD OF REVIEW
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.'”
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.
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
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
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