Reeves-Stanford v. Comm'r of Soc. Sec.
| Docket Number | 8:22-cv-1070-JSS |
| Decision Date | 03 August 2023 |
| Parties | REBECCA REEVES-STANFORD, Plaintiff, v. COMMISSIONER OF SOCIAL SECURITY, Defendant. |
| Court | U.S. District Court — Middle District of Florida |
Plaintiff Rebecca Reeves-Stanford seeks judicial review of the denial of her claim for spousal benefits based on the earnings record of her husband. As the Commissioner's decision was not based on substantial evidence, the decision is remanded.
On June 18, 2018, Plaintiff applied for spousal insurance benefits pursuant to 42 U.S.C. § 402(b) based on the earnings record of her husband, Robert Stanford. (Tr. 146-47.) Mr Stanford has been incarcerated in federal prison since at least 2012. (Tr. 44-45.) The Social Security Administration (SSA) initially denied Plaintiff's claim because Mr Stanford had not yet filed his own application for benefits. (Tr. 93-94.) Plaintiff requested reconsideration of the SSA's decision. (Tr. 95-98.) On reconsideration, the SSA affirmed its decision and concluded that “[s]ince [Plaintiff's] husband is not currently entitled to either retirement or disability benefits from Social Security, [Plaintiff is] not entitled to wife's benefits on his record.” (Tr. 99-101 (citing 42 U.S.C. § 402(b); 20 C.F.R. § 404.330).) Plaintiff then requested a hearing before an Administrative Law Judge (ALJ). (Tr 102-06.) The ALJ held a hearing on June 15, 2021, at which Plaintiff appeared and testified. (Tr. 34-56.) After the hearing, the ALJ issued a fully favorable decision dated June 22, 2021, finding Plaintiff entitled to spousal benefits on the record of her husband. (Tr. 25-33.) The ALJ acknowledged that “Social Security policy is that a current spouse cannot receive benefits on the account of her wage earner husband unless and until the husband files for Title II benefits on his own account” but found that the “wage earner/prisoner had applied for Title II retirement insurance benefits and [Plaintiff] is entitled to Title II spouse's benefits on the record of the wage earner/prisoner[.]” (Tr. 30.)
Following the ALJ's decision, an SSA Assistant Regional Commissioner sent a memorandum to the SSA Appeals Council arguing that the ALJ's decision “is not supported by the requirements of the [Social Security] Act” and Plaintiff is not entitled to benefits because “the wage earner has not filed for Title II benefits on his own account.” (Tr. 131.) The Memorandum noted that “prior online applications were attempted” on behalf of Mr. Stanford, but “were identified as possible anomalous filings” and the SSA “was unable to verify that the wage earner had indeed filed the applications.” (Tr. 131-32.) The applications were therefore “abated with no decision made[.]” (Tr. 132.)
The Appeals Council then reviewed the ALJ's decision sua sponte and permitted Plaintiff to submit additional argument and evidence in support of her claim, which she did. (Tr. 135-38.) On March 9, 2022, the Appeals Council reversed the ALJ's decision and issued an unfavorable decision finding that Plaintiff was not entitled to spousal benefits pursuant to 42 U.S.C. § 402(b). (Tr. 1-8.) On review of the record, the Appeals Council found that Mr. Stanford had “started online applications for retirement insurance benefits on his own record; however the Social Security Administration has not determined that he filed a valid application, nor has it awarded him entitlement to retirement insurance benefits on his own record.” (Tr. 6.) Accordingly, the Appeals Council concluded that Plaintiff was “not entitled to spouse's insurance benefits on the record of the wage earner” because Mr. Stanford had not filed a valid application and was therefore not entitled to benefits on his own record. (Tr. 6.)
Plaintiff timely filed a complaint with this court seeking judicial review of the Appeals Council's decision. (Dkt. 1.) The case is now ripe for review under 42 U.S.C. § 405(g). Before the court are Plaintiff's brief in opposition to the Commissioner's decision (Dkt. 20), Defendant's brief in support of the Commissioner's decision (Dkt. 23), and Plaintiff's reply brief (Dkt. 24).
An individual may obtain judicial review of any final decision of the Commissioner of Social Security through a civil action brought in a district court of the United States. 42 U.S.C. § 405(g). On review, the court must uphold a determination by the Commissioner that a claimant is not entitled to benefits if it is supported by substantial evidence and comports with applicable legal standards. See id. “[I]n cases where the Appeals Council reverses an ALJ's decision on its own motion, judicial review is limited to determining whether the Appeals Council's decision is supported by substantial evidence.” Parker v. Bowen, 788 F.2d 1512, 151920 (11th Cir. 1986). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971) (quoting Consol. Edison Co. v. N.L.R.B., 305 U.S. 197, 229 (1938)); Miles v. Chater, 84 F.3d 1397, 1400 (11th Cir. 1996).
In reviewing the Commissioner's decision, the court may not decide the facts anew, re-weigh the evidence, or substitute its own judgment for that of the ALJ or Appeals Council, even if it finds that the evidence preponderates against the Commissioner's decision. Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983). The Commissioner's failure to apply the correct law, or to give the reviewing court sufficient reasoning for determining that he or she has conducted the proper legal analysis, mandates reversal. Keeton v. Dep't of Health & Hum. Servs., 21 F.3d 1064, 1066 (11th Cir. 1994). The scope of review is thus limited to determining whether the findings of the Commissioner are supported by substantial evidence and whether the correct legal standards were applied. 42 U.S.C. § 405(g); Wilson v. Barnhart, 284 F.3d 1219, 1221 (11th Cir. 2002).
Plaintiff challenges the Appeals Council's decision and argues that remand is warranted for two reasons. (Dkt. 20.) First Plaintiff argues that the Appeals Council erred in interpreting the relevant statute and regulation to require that Mr. Stanford must have filed a valid application for benefits before Plaintiff would be entitled to spousal benefits. (id. at 10-13.) Second, Plaintiff argues that the Appeals Council's finding that Mr. Stanford had not applied for benefits is not supported by substantial evidence. (id. at 14-16.) For the reasons that follow, Plaintiff's second contention warrants reversal.
When an administrative agency, such as the SSA, interprets a statute or regulation that it administers, a court reviews the agency's interpretation de novo, although potentially with some level of deference to the agency's interpretation. Martin v. Soc. Sec. Admin., 903 F.3d 1154, 1159 (11th Cir. 2018) (citing Arevalo v. U.S. Att'y Gen., 872 F.3d 1184, 1187 (11th Cir. 2017)); see Chevron, U.S.A., Inc. v. Nat. Res. Def. Council, Inc., 467 U.S. 837 (1984). The proper level of deference to be given to an agency's interpretation is determined by the “circumstances of each case, including the presence of congressionally delegated agency authority, the form of the agency action and, for those situations not clearly meriting Chevron deference, the factors laid out in Skidmore v. Swift & Co., 323 U.S. 134, 140 [] (1944).” Stroup v. Barnhart, 327 F.3d 1258, 1261 (11th Cir. 2003) (citing United States v. Mead Corp., 533 U.S. 218, 227-35 (2001)).
Under any standard of deference however, the court's analysis must begin with the text of the statute or regulation to determine whether the language “has a plain and unambiguous meaning.” Martin, 903 F.3d at 1163 (quoting United States v. Williams, 790 F.3d 1240, 1245 (11th Cir. 2015)); see also Dobson v. Sec'y of Health & Hum. Servs., No. 20-11996, 2022 WL 424813, at *6 (11th Cir. Feb. 11, 2022) () (citing Kisor v. Wilkie, 139 S.Ct. 2400, 2414 (2019)). If the text is “plain and unambiguous, there is no need for further inquiry.” Sec. & Exch. Comm'n v. Levin, 849 F.3d 995, 1003 (11th Cir. 2017) (quoting CBS Broad. Inc. v. Echostar Commc'ns Corp., 532 F.3d 1294, 1300-01 (11th Cir. 2008)). The court must give effect to the text's plain and unambiguous meaning and no deference is given to the agency's interpretation. Arevalo, 872 F.3d at 1188 (citing Carcieri v. Salazar, 555 U.S. 379, 387 (2009)); see also Nat'l Coal Ass'n v. Chater, 81 F.3d 1077, 1081-82 (11th Cir. 1996) (citing Griffin v. Oceanic Contractors, Inc., 458 U.S. 564, 570 (1982)). The court's first step is thus “to determine whether the statutory language has a plain and unambiguous meaning by referring to the language itself, the specific context in which that language is used, and the broader context of the statute as a whole.” Levin, 849 F.3d at 1003 (quoting Bautista v. Star Cruises, 396 F.3d 1289, 1295 (11th Cir. 2005)); see also Smith v. Berryhill, 139 S.Ct. 1765, 1774 (2019) ().
If the text is silent or ambiguous on the issue, the court may defer to the agency's interpretation of the text pursuant to the standards set by the Supreme Court. Martin, 903 F.3d at 1159. In certain circumstances, the agency's interpretation will warrant heightened deference pursuant to the Supreme Court's decision in Chevron, under which the court “must defer to an agency's reasonable interpretation of an ambiguous statute.” Id. ...
To continue reading
Request your trial