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Little v. U.S.

Facts

Alissa Leslie Little filed an application for disability insurance benefits on November 28, 2018, claiming she was disabled since July 24, 2018. After her claim was denied at the initial level, she requested a hearing where she testified before an ALJ. The ALJ found that Little had severe impairments including Degenerative Disc Disease, Bipolar Disorder, and Generalized Anxiety Disorder, but concluded that she was not disabled as of the date of the decision.

[Little] alleges disability secondary to mixed physical and mental health disorders that cause back pain that radiates to the legs, decreased range of motion, weakness, poor concentration, loss of focus, mood changes, social anxiousness, irritability, tearfulness, paranoia, and impulsiveness. She describes the lower back pain as moderate constant pain to severe sharp and shooting pain. Medications cause daytime fatigue. The symptoms and medication side effects allegedly affect lifting, squatting, bending, standing, reaching, walking, sitting, kneeling, climbing stairs, memory, completing tasks, concentration, understanding, following instructions, using hands, and getting along with others.

Issue

The main legal issue was whether substantial evidence supported the Commissioner's finding that Little was not disabled under the Social Security Act.

The question before this court, therefore, is not whether Little is disabled, but whether substantial evidence supports the Commissioner's finding that she is not disabled and whether the Commissioner correctly applied the relevant law.

Rule

The court applied the substantial evidence standard, which requires that the Commissioner's factual findings be supported by such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.

When reviewing the Commissioner's final decision denying a claimant's application for benefits, 'the court has plenary review of all legal issues decided by the Commissioner.' Ficca v. Astrue, 901 F. Supp. 2d 533, 536 (M.D. Pa. 2012). But the court's review of the Commissioner's factual findings is limited to whether substantial evidence supports those findings. See 42 U.S.C. 405(g); Biestek v. Berryhill, 139 S. Ct. 1148, 1152, 203 L. Ed. 2d 504 (2019).

Analysis

The court analyzed the ALJ's application of the sequential-evaluation process, which included determining whether Little engaged in substantial gainful activity, had severe impairments, and whether those impairments met or equaled a listed impairment. The ALJ's findings regarding Little's limitations and the evidence presented were scrutinized, and it was determined that the ALJ's conclusions were supported by substantial evidence.

The ALJ's disability determination must also meet certain basic substantive requisites. Most significantly, the ALJ must provide 'a clear and satisfactory explication of the basis on which' his or her decision rests. Cotter v. Harris, 642 F.2d 700, 704 (3d Cir. 1981). 'The ALJ must indicate in his decision which evidence he has rejected and which he is relying on as the basis for his finding.' Schaudeck v. Comm'r of Soc. Sec. Admin., 181 F. 3d 429, 433 (3d Cir. 1999).

Conclusion

The court affirmed the Commissioner's decision, concluding that substantial evidence supported the finding that Little was not disabled.

For the reasons set forth below, we will affirm the Commissioner's decision and enter judgment in favor of the Commissioner.

Who won?

The Commissioner prevailed in the case because the court found that the decision to deny Little's claim for benefits was supported by substantial evidence.

The Commissioner then filed an answer and a certified transcript of the administrative proceedings. Docs. 9, 10. The parties filed briefs, see docs. 17, 18, and this matter is ripe for decision.

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