The opinion of the court was delivered by: POLITAN
Plaintiff Michael Edwards brings this action before the Court seeking to overturn the final determination of the Commissioner of Social Security denying plaintiff's claim for disability insurance benefits and Supplemental Security Income ("SSI"). For the following reasons, the Commissioner's decision is hereby affirmed.
Plaintiff Michael Edwards filed applications for Social Security disability insurance benefits and SSI on June 8, 1993, alleging disability due to a back condition, cervical left leg sprain, and right eye problems. Plaintiff's claim for benefits was initially denied, and then subsequently denied on reconsideration. Next, the plaintiff requested a hearing before the Administrative Law Judge ("ALJ"). A hearing before ALJ Richard DeSteno was then scheduled for November 9, 1995. At this hearing, the ALJ denied plaintiff's request for recusal.
On March 14, 1996, the ALJ determined that plaintiff was not disabled and thus not entitled to Social Security benefits. In ruling that Edwards was not disabled, the ALJ determined that the evidence did not establish that Edwards's impairments satisfied the requirements set forth in the "Listing of Impairments." See C.F.R. § 404, Subpt. P, App.1 (1995). In addition, the ALJ decided that the plaintiff's subjective complaints were controverted by the medical evidence; thus, the ALJ did not accord much weight to these complaints. Next, at step four, the ALJ found that plaintiff did not have the ability to perform his prior occupational duties.
The ALJ then proceeded to step five, however, and found that plaintiff has performed some work which involved the lifting of objects, sitting and standing for eight hours a day, and a full range of sedentary work. Based on this finding, the ALJ concluded that the plaintiff did not have any significant nonexertional impairments. The ALJ then utilized the Medical-Vocational grids endorsed by the Third Circuit and determined that Edwards did have the residual functional capacity to perform jobs existing in the national economy. Accordingly, the ALJ concluded that plaintiff was not disabled and, therefore, not entitled to benefits.
The Appeals Council then denied plaintiff's request for review, and this appeal followed.
Jurisdiction over this appeal is conferred upon this Court pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3). Based on § 405(g), this Court must affirm the Commissioner's findings of fact if supported by substantial evidence. It is settled that substantial evidence means any "'such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.'" Richardson v. Perales, 402 U.S. 389, 401, 28 L. Ed. 2d 842, 91 S. Ct. 1420 (1971) (quoting Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 83 L. Ed. 126, 59 S. Ct. 206 (1938)). In addition, the ALJ's ruling should clearly explain the foundation upon which it rests. Cotter v. Harris, 642 F.2d 700, 704 (3d Cir. 1981). Furthermore, it is clear that the ALJ is charged with the responsibility of analyzing all the relevant evidence and explaining why certain evidence was considered relevant while other evidence was dismissed. Gober v. Matthews, 574 F.2d 772, 776 (3d Cir. 1978). Although administrative decisions are accorded a certain level of deference, it is the responsibility of this Court to closely sift through the record in order to determine whether the ALJ's ruling is buttressed by substantial evidence. Id.
In order for a claimant to be deemed disabled, and thus be entitled to benefits, he or she must comply with all relevant statutory requirements. To comply, the claimant must first meet the insured status requirements listed in 42 U.S.C. § 423(c) and the resource and income restrictions set forth in 42 U.S.C. §§ 1382(a) and (b). Secondly, the claimant must establish that he is not engaged in substantial gainful activity as defined in §§ 423(d)(1)(A) and 1382(c)(3)(A). In the instant case, the plaintiff has satisfied both of these requirements.
Finally, the claimant must show that he is disabled as defined by the statute. This final determination is the issue on appeal, and this Court must decide if the ALJ's ruling denying the plaintiff "disabled" status is supported by substantial evidence.
The Social Security Act prescribes a five-step process that must be satisfied in order for a claimant to be entitled to benefits. See 20 C.F.R. § 404.1520 (1995). Initially, the plaintiff has the burden of establishing that he is not currently employed or engaged in "substantial gainful activity." 20 C.F.R. § 404.1520(a) (1995); Bowen v. Yuckert, 482 U.S. 137, 146-47 n.5, 96 L. Ed. 2d 119, 107 S. Ct. 2287 (1987). Then, the plaintiff must also prove that he is inflicted with a severe medical impairment. 20 C.F.R. § 404.1520(c) (1995); Bowen, 482 U.S. at 146-47 n.5. In addition, as a third requisite, the ALJ must determine whether the severe impairment is listed in 20 C.F.R. § 404, Subpt. P, App. 1 (1995). If the claimant's impairment does not meet the criteria set forth in the list of impairments, the ALJ must move to step four.
Pursuant to step four, the claimant is under the obligation to prove that he or she cannot return to the particular type of work the claimant had previously performed. 20 C.F.R. § 404.1520(e) (1995); Bowen, 482 U.S. at 146-47 n.5. Failure to prove this requisite will result in a denial of benefits. 20 C.F.R. § 404.1520(e) (1995). Finally, if the claimant has proven that he or she is unable to perform prior occupational duties, the burden then shifts to the Commissioner to establish that the claimant is able to work in some other occupation in the ...