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Chandler v. Colvin

United States District Court, D. South Carolina, Anderson/Greenwood Division

September 26, 2014

CAROLYN W. COLVIN, Acting Commissioner of Social Security, Respondent.


DAVID C. NORTON, District Judge.

This matter is before the court on United States Magistrate Judge Jacquelyn D. Austin's Report and Recommendation ("R&R") that the court affirm the Acting Commissioner of Social Security Carolyn W. Colvin's decision denying claimant Angela Chandler's ("Chandler") application for supplemental security income ("SSI"). Chandler has filed objections to the R&R. For the reasons set forth below, the court adopts the R&R and affirms the Commissioner's decision.


Unless otherwise noted, the following background is drawn from the R&R.

A. Procedural History

Chandler filed an application for SSI on January 6, 2011, alleging that she had been disabled since August 1, 2002. The Social Security Administration ("the Agency") denied Chandler's application both initially and on reconsideration. Chandler requested a hearing before an administrative law judge ("ALJ") and ALJ Augustus C. Martin presided over a hearing held on January 20, 2012. In a decision issued on February 14, 2012, the ALJ determined that Chandler was not disabled. This decision became the final decision of the Commissioner when the Appeals Council denied further review on March 20, 2103.

Chandler filed this action for judicial review on May 15, 2013. On October 23, 2013, she filed a brief requesting that the Commissioner's decision be reversed and the case remanded to the Agency for further administrative proceedings. On December 4, 2013, the Commissioner filed a brief contending that her decision should be upheld. On August 4, 2014, the magistrate judge issued the R&R, recommending that the Commissioner's decision be affirmed. Chandler objected to the R&R on August 19, 2014, and the Commissioner responded to Chandler's objections on August 28, 2014. This matter has been fully briefed and is now ripe for the court's review.

B. Chandler's Medical History

Because the parties are familiar with Chandler's medical history, the court dispenses with a lengthy recitation thereof and instead notes a few relevant facts. Chandler was born on March 5, 1959, and was forty-three years old on her alleged disability onset date. She has an eighth grade education, and past relevant work experience as a housekeeper and restaurant worker.

C. ALJ's Findings

The Social Security Act defines "disability" as 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 12 months." 42 U.S.C. § 423(d)(1)(A); 20 C.F.R. § 404.1505. The Social Security regulations establish a fivestep sequential evaluation process to determine whether a claimant is disabled. See 20 C.F.R. §§ 404.1520, 416.920. Under this process, the ALJ must determine whether the claimant: (1) is currently engaged in substantial gainful activity; (2) has a severe impairment; (3) has an impairment which equals an impairment contained in 20 C.F.R. § 404, Subpt. P, App'x 1, which warrants a finding of disability without considering vocational factors; (4) if not, whether the claimant has an impairment which prevents her from performing past relevant work; and (5) if so, whether the claimant is able to perform other work considering both her remaining physical and mental capacities (defined by her residual functional capacity) and her vocational capabilities (age, education, and past work experience) to adjust to a new job. See 20 C.F.R. § 404.1520; Hall v. Harris , 658 F.2d 260, 264-65 (4th Cir. 1981). The claimant bears the burden of proof during the first four steps of the inquiry, while the burden shifts to the Commissioner for the final step. Pass v. Chater , 65 F.3d 1200, 1203 (4th Cir. 1995) (citing Hunter v. Sullivan , 993 F.2d 31, 35 (4th Cir. 1992)).

To determine whether Chandler was disabled from August 1, 2002 through the date of his decision, the ALJ employed the statutorily-required five-step sequential evaluation process. At step one, the ALJ found that Chandler did not engage in substantial gainful activity during the period at issue. Tr. 14. At step two, the ALJ found that Chandler suffered from the following severe impairments: major depressive disorder and post-traumatic stress disorder. Id . At step three, the ALJ found that Chandler's impairments or combination thereof did not meet or medically equal one of the impairments listed in the Agency's Listing of Impairments. Tr. 15. Before reaching the fourth step, the ALJ determined that Chandler retained the residual functional capacity ("RFC")

to perform a full range of work at all exertional levels but with the following non-exertional limitations: the claimant can perform only simple, routine and repetitive tasks. Additionally, she is limited to a job that does not require working in close proximity to or close coordination with co-workers and does not require continuous interaction with the public. The claimant also requires a low-stress work environment, meaning no production quotas and minimal decision making.

Tr. 17. At step four, the ALJ found that Chandler had no past relevant work, as that term is defined in the regulations. Tr. 20. Finally, at the fifth step, the ALJ found that Chandler could perform jobs existing in significant numbers in the national economy and ...

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