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Sober v. Saul

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

December 12, 2019

KIRT D. SOBER, Plaintiff,
v.
ANDREW M. SAUL, Commissioner of the Social Security Administration, [1] Defendant.

          MEMORANDUM OPINION

          ABDUL K. KALLON UNITED STATES DISTRICT JUDGE

         Kirt D. Sober 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”). For the reasons explained below, the court finds that the Administrative Law Judge (“ALJ”) applied the correct legal standards and that the ALJ's decision, which has become the final decision by the Commissioner, is supported by substantial evidence. Therefore, the court affirms the decision denying benefits.

         I. PROCEDURAL HISTORY

         Sober filed applications for disability insurance benefits and supplemental security income, alleging that he suffered from a disability beginning June 20, 2015, due to bipolar disorder, back issues, status post knee surgery, and depression. R. 91, 174, 181, 192. After the SSA denied Sober's applications, R. 121, 124-25, he requested a formal hearing, R. 137. Subsequently, an ALJ entered a decision finding that Sober was not disabled, R. 59-72. The SSA Appeals Council denied Sober's request for review, see R. 16, 163, and summarily affirmed the ALJ's decision denying disability benefits, rendering the ALJ's decision the final decision of the Commissioner, R. 1-2. Having exhausted his administrative remedies, Sober 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 ...

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