United States District Court, M.D. North Carolina
MELISSA M. JAYNES, Plaintiff,
CAROLYN W. COLVIN, Acting Commissioner of Social Security,  Defendant.
MEMORANDUM OPINION AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE
L. PATRICK AULD, Magistrate Judge.
Plaintiff, Melissa M. Jaynes, brought this action pursuant to the Social Security Act (the "Act") to obtain judicial review of a final decision of Defendant, the Commissioner of Social Security, denying Plaintiff's claim(s) for Disability Insurance Benefits ("DIB") and Supplemental Security Income ("SSI"). (Docket Entry 1.) The Court has before it the certified administrative record (cited herein as "Tr. __"), as well as the parties' cross-motions for judgment (Docket Entries 19, 21). For the reasons that follow, the Court should enter judgment for Defendant.
Plaintiff applied for DIB and SSI in December 2008, alleging a disability onset date of September 19, 2008. (Tr. 137-43.) Upon denial of the application(s) initially (Tr. 45, 46) and on reconsideration (Tr. 47, 48), she requested a hearing de novo before an Administrative Law Judge ("ALJ") (Tr. 70-71). Plaintiff and her attorney attended the hearing on June 2, 2010. (Tr. 22-40.) By decision dated June 16, 2010, the ALJ ruled Plaintiff not disabled under the Act. (Tr. 6-21.) The Appeals Council subsequently denied Plaintiff's request for review, making the ALJ's ruling the Commissioner's final decision for purposes of judicial review. (Tr. 1-3.)
In rendering that disability determination, the ALJ made the following findings later adopted by the Commissioner:
1. [Plaintiff] meets the insured status requirements of the... Act through December 31, 2013.
2. [Plaintiff] has not engaged in substantial gainful activity since... the alleged onset date....
3. [Plaintiff] has the following severe impairments: obesity, a history of attention deficit disorder, the affective disorder of bipolar syndrome I, a borderline personality disorder, and poly-substance use disorder....
4. [Plaintiff] does not have an impairment or combination of impairments that meets or medically equals one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1....
5.... [Plaintiff] has the residual functional capacity to perform medium work as defined in 20 CFR 404.1567(c) and 416.967(c) except that she is limited to simple, routine, repetitive tasks in a low-stress environment with low levels of social interaction.
(Tr. 11-14.) In light of the foregoing findings regarding residual functional capacity ("RFC"), the ALJ ruled that Plaintiff could not perform her past relevant work. (Tr. 16.) However, the ALJ concluded that, "[c]onsidering [Plaintiff's] age, education, work experience, and [RFC], there are jobs that exist in significant numbers in the national economy that [Plaintiff] can perform." (Id.) Accordingly, the ALJ found that Plaintiff did not suffer from a "disability, " as defined in the Act, at any time from the alleged onset date through the date of decision. (Tr. 17.)
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). However, "the scope of [judicial] review of [such] a decision... is extremely limited." Frady v. Harris , 646 F.2d 143, 144 (4th Cir. 1981). "The courts are not to try the case de novo." Oppenheim v. Finch , 495 F.2d 396, 397 (4th Cir. 1974). Instead, "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." Hines , 453 F.3d at 561 (internal brackets and quotation marks omitted).
"Substantial evidence means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.'" Hunter v. Sullivan , 993 F.2d 31, 34 (4th Cir. 1992) (quoting Richardson v. Perales , 402 U.S. 389, 390 (1971)). "It consists of more than a mere scintilla of evidence but may be somewhat less than a preponderance." Mastro v. Apfel , 270 F.3d 171, 176 (4th Cir. 2001) (internal brackets and quotation marks omitted). "If there is evidence to justify a refusal to direct a ...