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Degraffenfrid v. Colvin

United States District Court, D. Massachusetts

September 20, 2016

CAROLYN COLVIN, Commissioner of Social Security, Defendant.



         Plaintiff Helen Degraffenreid (“Ms. Degraffenreid” or “Claimant”) brings this action pursuant to section 205(g) of the Social Security Act, 42 U.S.C. § 405(g), challenging the final decision of the Commissioner of the Social Security Administration (the “Commissioner”) denying her claim for Social Security Disability Insurance (“SSDI”) and Supplemental Security Income (“SSI”) benefits. Currently pending are Claimant's motion to reverse the Commissioner's decision denying her disability benefits [ECF No. 17], and the Commissioner's cross-motion for an order affirming the decision. [ECF No. 18]. For the reasons described herein, the Court finds that the ALJ's decision was supported by substantial evidence and therefore DENIES Claimant's motion to reverse and remand and ALLOWS the Commissioner's motion to affirm.

         I. Background

         a. Statutory and Regulatory Framework: Five-Step Process to Evaluate Disability Claims

         “The Social Security Administration is the federal agency charged with administering both the Social Security disability benefits program, which provides disability insurance for covered workers, and the Supplemental Security Income program, which provides assistance for the indigent aged and disabled.” Seavey v. Barnhart, 276 F.3d 1, 5 (1st Cir. 2001) (citing 42 U.S.C. §§ 423, 1381a).

         The Social Security Act (the “Act”) provides that an individual shall be considered to be “disabled” if he or she is:

unable 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 that has lasted or can be expected to last for a continuous period of not less than twelve months.

42 U.S.C. § 1382c(a)(3)(A); see also 42 U.S.C. § 423(d)(1)(A). The inability must be severe, such that the claimant is unable to do his or her previous work or any other substantial gainful activity that exists in the national economy. See 42 U.S.C. § 1382c(a)(3)(B); 20 C.F.R. § 416.905.

         When evaluating a disability claim under the Act, the Commissioner uses a five-step process, which the First Circuit has explained as follows:

All five steps are not applied to every applicant, as the determination may be concluded at any step along the process. The steps are: 1) if the applicant is engaged in substantial gainful work activity, the application is denied; 2) if the applicant does not have, or has not had within the relevant time period, a severe impairment or combination of impairments, the application is denied; 3) if the impairment meets the conditions for one of the “listed” impairments in the Social Security regulations, then the application is granted; 4) if the applicant's “residual functional capacity” is such that he or she can still perform past relevant work, then the application is denied; 5) if the applicant, given his or her residual functional capacity, education, work experience, and age, is unable to do any other work, the application is granted.

Seavey, 276 F.3d at 5 (citing 20 C.F.R. § 416.920).

         Where the record includes medical evidence of drug addiction or alcoholism (“DAA”), there is an additional step: the Commissioner must determine whether the DAA is a “contributing factor material to the determination of disability.” 20 C.F.R. § 404.1535. This is because, “[a]n individual shall not be considered . . . disabled . . . if alcoholism or drug addiction would . . . be a contributing factor material to the Commissioner's determination that the individual is disabled.” 42 U.S.C. § 1382c (a)(3)(J)). “The key factor . . . in determining whether drug addiction or alcoholism is a contributing factor material to the determination of disability is whether [the Commissioner] would still find [the claimant] disabled if [the claimant] stopped using drugs or alcohol.” 20 C.F.R. § 404.1535. Accordingly, where there is medical evidence of DAA, the ALJ repeats the five-step analysis to determine if the claimant would be disabled even if he or she stopped using drugs or alcohol.

         b. Procedural Background

         Ms. Degraffenreid filed her application for SSI benefits on June 21, 2013 and for SSDI benefits on June 29, 2013. [R. 291-302].[1] She alleged that she became disabled on February 8, 2012, due to a combination of impairments including depression, anxiety, bipolar disorder, attention deficit disorder, and post-traumatic stress disorder. [R. 292]. Her date last insured was June 30, 2013. [R. 313].

         The Social Security Administration (the “SSA”) denied Ms. Degraffenreid's applications for SSI and SSDI benefits on September 3, 2013, and again upon reconsideration on January 24, 2014. [R. 138-139, 178-179]. Thereafter, Ms. Degraffenreid requested an administrative hearing [R. 195-196], and a hearing took place before Administrative Law Judge (“ALJ”) Paul W. Goodale on August 14, 2014. [R. 28-104]. Ms. Degraffenreid, who was represented by counsel, appeared and testified at the hearing, as did a vocational expert (“VE”). On September 23, 2014, the ALJ issued a decision finding that Ms. Degraffenreid was not disabled. [R. 10-22]. The SSA Appeals Council denied Ms. Degraffenreid's Request for Review on November 26, 2014 [R. 1-4]. On January 23, 2015, Ms. Degraffenreid filed a timely Complaint with this Court, seeking review of the Commissioner's decision pursuant to section 205(g) of the Act. [ECF No. 1].

         c. Factual Background

         Ms. Degraffenreid was born on July 23, 1971 and was raised in Somerville and Woburn, Massachusetts. [R. 105; 1034]. She graduated from Woburn High School. [R. 653]. She has two daughters, who both live with their father. [R. 299]. Ms. Degraffenreid has had periods of homelessness and lost custody of her children as a result of her unstable living situation and alcohol use. [R. 653]. Ms. ...

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