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Chaney v. Colvin

United States District Court, M.D. North Carolina

March 28, 2014

JAMES E. CHANEY, Plaintiff,
v.
CAROLYN W. COLVIN, [1] Commissioner of Social Security, Defendant.

MEMORANDUM OPINION AND ORDER

CATHERINE C. EAGLES, District Judge.

Plaintiff James Chaney brought this action pursuant to Sections 205(g) and 1631(c)(3) of the Social Security Act (the "Act"), as amended, 42 U.S.C. §§ 405(g), 1383(c)(3), to obtain judicial review of a final decision of the Commissioner of Social Security denying his claim for Disability Insurance Benefits under Title II of the Act. The parties have filed cross-motions for judgment, (Docs. 9, 11), and the administrative record has been certified to the Court for review.

I. PROCEDURAL HISTORY

Mr. Chaney protectively filed his application for Disability Insurance Benefits on March 29, 2007, alleging a disability onset date of January 2, 2007. (Tr. at 15, 87-88, 103.)[2] His application was denied initially, ( id. at 51, 53-56), and upon reconsideration. ( Id. at 52, 60-62.) Thereafter, Mr. Chaney requested a hearing de novo before an Administrative Law Judge ("ALJ"). ( Id. at 63-67.) After a hearing, the ALJ determined that Mr. Chaney was not disabled within the meaning of the Act, ( id. at 24), and, on August 5, 2009, the Appeals Council denied Mr. Chaney's request for review of the decision, thereby making the ALJ's conclusion the Commissioner's final decision for purposes of judicial review. ( Id. at 1-4.)

II. LEGAL STANDARD

Federal law "authorizes judicial review of the Social Security Commissioner's denial of social security benefits." Hines v. Barnhart, 453 F.3d 559, 561 (4th Cir. 2006). "[T]he scope of [the court's] review of [such an administrative] decision... is extremely limited." Frady v. Harris, 646 F.2d 143, 144 (4th Cir. 1981). "[A] reviewing court must uphold the factual findings of the ALJ [underlying the denial of benefits] if they are supported by substantial evidence and were reached through application of the correct legal standard." Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012) (quotation marks and internal alterations omitted). The issue before this Court "is not whether [the claimant] is disabled, but whether the ALJ's finding that [the claimant] is not disabled is supported by substantial evidence and was reached based upon a correct application of the relevant law." Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996).

"The Commissioner uses a five-step process to evaluate disability claims." Hancock, 667 F.3d at 472 (citing 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4)). The Commissioner asks whether the claimant "(1) worked during the alleged period of disability; (2) had a severe impairment; (3) had an impairment that met or equaled the requirements of a listed impairment; (4) could return to her past relevant work; and (5) if not, could perform any other work in the national economy." Id.

III. THE ALJ'S DECISION

The ALJ found at step one that Mr. Chaney had not engaged in "substantial gainful activity" since his alleged onset date. (Tr. at 17.) At step two, the ALJ determined that Mr. Chaney suffered from five severe impairments: mild to moderate arthritis of the left knee, early degenerative changes in the lumbar spine at L3-4 and L4-5, sleep apnea, fibromyalgia, and depression. ( Id. ) The ALJ found at step three that none of these impairments met or equaled a disability listing. ( Id. at 18.) Accordingly, the ALJ assessed Mr. Chaney's RFC and determined that he could perform the full range of medium work as defined in 20 C.F.R. § 404.1567(c). ( Id. at 19.) Although the ALJ found at step four of the analysis that Mr. Chaney could not return to his past relevant work, he found at step five that, given Mr. Chaney's age, education, work experience, and RFC, he could perform other jobs that exist in significant numbers in the national economy and therefore was not disabled. ( Id. at 23-24.)

IV. CONTENTIONS

Mr. Chaney now argues that substantial evidence fails to support the ALJ's credibility finding. Specifically, Mr. Chaney contends that the ALJ mischaracterized both his ability to perform household chores and his reason for stopping work. (Doc. 10 at 3-5.)

V. DISCUSSION

In Craig v. Chater , the Fourth Circuit provides a two-part test for evaluating a claimant's statements about symptoms. "First, there must be objective medical evidence showing the existence of a medical impairment(s) which results from anatomical, physiological, or psychological abnormalities and which could reasonably be expected to produce the pain or other symptoms alleged.'" 76 F.3d at 594 (citing 20 C.F.R. §§ 416.929(b) and 404.1529(b)) (internal alterations omitted). If the ALJ determines that such an impairment exists, the second part of the test then requires him to consider all available evidence, including the plaintiff's statements about his pain, in order to determine whether the plaintiff is disabled. Craig, 76 F.3d at 595-96.

While the ALJ must consider the plaintiff's statements and other subjective evidence at step two, he need not credit them to the extent they conflict with the objective medical evidence or to the extent that the underlying impairment could not reasonably be expected to cause the symptoms alleged. Id. at 596. Relevant evidence for this inquiry includes the plaintiff's "medical history, medical ...


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