## Facts

- Maxine Barnes, age 41, had a high-school-equivalent education, some mechanics training, and work experience including construction laborer, heavy-equipment operator, machinist, and sewing-machine operator.
- Barnes applied for disability insurance benefits on December 20, 1984, alleging disabling impairments including a back injury and pain.
- The agency denied the claim initially and on reconsideration; an ALJ found Barnes not disabled, and the Appeals Council denied review.
- Barnes sought judicial review; the district court remanded because the first ALJ relied solely on the Medical–Vocational Guidelines.
- On remand, a second ALJ found Barnes not disabled at step four, concluding she retained the residual functional capacity to perform past work as a sewing-machine operator.
- The Appeals Council adopted the second ALJ’s decision; the district court affirmed the denial of benefits.
- On appeal, Barnes argued her sewing-machine operator job did not qualify as “past relevant work” because it was too remote in time and not sufficiently continuous under 20 C.F.R. § 404.1565.

## Issues

1. Whether substantial evidence supported the agency’s determination that Barnes’s sewing-machine operator job qualified as “past relevant work” under 20 C.F.R. § 404.1565, despite remoteness in time.
2. Whether substantial evidence supported the finding that Barnes retained the residual functional capacity to perform that past relevant work, justifying a step-four denial of benefits.

## Decision

- The Eleventh Circuit affirmed the district court’s judgment and the Secretary’s denial of benefits.
- The court held substantial evidence supported treating Barnes’s sewing-machine operator job as past relevant work under 20 C.F.R. § 404.1565.
- The court held substantial evidence supported the residual functional capacity finding that Barnes could perform the sewing-machine operator job.
- The court reiterated that judicial review does not permit reweighing evidence or substituting judicial judgment for the agency’s factual findings when supported by substantial evidence.

## Legal Principles

- A claimant is not disabled at step four if she can perform her past relevant work.
- Under 20 C.F.R. § 404.1565, past relevant work generally includes work performed within the last 15 years, performed long enough to learn it, and performed at substantial gainful activity levels; the 15-year period functions as a guideline rather than an absolute bar.
- In Social Security appeals, agency fact findings are conclusive if supported by substantial evidence, meaning more than a scintilla and less than a preponderance, evaluated on the record as a whole.
- Reviewing courts may not decide facts anew, reweigh evidence, or replace the agency’s judgment with their own if the correct legal standards were applied and substantial evidence supports the result.

## Conclusion

The Eleventh Circuit upheld the denial of disability insurance benefits because the administrative record contained substantial evidence that Barnes’s prior sewing-machine operator work could be treated as past relevant work under § 404.1565 and that she retained the capacity to return to that work, warranting a step-four finding of no disability.


Barnes v. Sullivan, 932 F.2d 1356 (11th Cir. 1991)