Altland v. Saul

CourtDistrict Court, M.D. Pennsylvania
DecidedJanuary 18, 2022
Docket3:20-cv-02168
StatusUnknown

This text of Altland v. Saul (Altland v. Saul) is published on Counsel Stack Legal Research, covering District Court, M.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Altland v. Saul, (M.D. Pa. 2022).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA ELLEN ALTLAND,

Plaintiff, CIVIL ACTION NO. 3:20-CV-02168

v. (MEHALCHICK, M.J.)

KILOLO KIJAKAZI,1

Defendant.

MEMORANDUM Plaintiff Ellen Altland (“Altland”) brings this action under section 205(g) of the Social Security Act, 42 U.S.C. § 405(g), for judicial review of the final decision of the Commissioner of Social Security (the “Commissioner”) denying her application for disability insurance benefits under Title II of the Social Security Act. (Doc. 1). This matter has been referred to the undersigned United States Magistrate Judge on consent of the parties, pursuant to the provisions of 28 U.S.C. §636(c) and Rule 73 of the Federal Rules of Civil Procedure. (Doc. 9). For the reasons expressed herein, and upon detailed consideration of the arguments raised by the parties in their respective briefs, it is hereby ordered that the Commissioner’s decision be AFFIRMED. I. BACKGROUND AND PROCEDURAL HISTORY On May 15, 2018, Altland protectively filed an application for Title II disability insurance benefits, claiming disability beginning August 11, 2015, due to Postural Orthostatic

1 The Court has amended the caption to replace, as the named defendant, Acting Social Security Commissioner Andrew Saul with his successor, Social Security Commissioner Kilolo Kijakazi. See Fed. R. Civ. P. 25(d) (“An action does not abate when a public officer who is a party in an official capacity dies, resigns, or otherwise ceases to hold office while the action is pending. The officer’s successor is automatically substituted as a party.”). Tachycardia Syndrome, Hypermobile Ehlers-Danlos Syndrome, asthma, joint pain, previous back injury, and seasonal affective disorder. (Doc. 16-6, at 4; Doc. 16-37, at 6). The Social Security Administration initially denied the application on August 16, 2018, prompting Altland’s request for a hearing, which Administrative Law Judge (“ALJ”) Gerard W. Langan

held on July 18, 2019. (Doc. 16-3, at 5; Doc. 16-5, at 2). In a written decision dated November 6, 2019, the ALJ determined that Altland is not disabled and therefore not entitled to benefits under Title II. (Doc. 16-2, at 13). On September 24, 2020, the Appeals Council denied Altland’s request for review. (Doc. 16-2, at 2). On November 19, 2020, Altland filed the instant action. (Doc. 1). The Commissioner responded on May 13, 2021, providing the requisite transcripts from Altland’s disability proceedings. (Doc. 15; Doc. 16). The parties then filed their respective briefs with Altland alleging one base for reversal or remand. (Doc. 19; Doc. 22). II. STANDARDS OF REVIEW To receive benefits under Title II of the Social Security Act, a claimant must

demonstrate an “inability 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 which has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A); 20 C.F.R. § 404.1509. To satisfy this requirement, a claimant must have a severe physical or mental impairment that makes it impossible to do his or her previous work or any other substantial gainful activity that exists in significant numbers in the national economy. 42 U.S.C. § 423(d)(2)(A); 20 C.F.R. § 404.1505(a).2 Additionally,

2 A “physical or mental impairment” is defined as an impairment resulting from

- 2 - to be eligible to receive Title II benefits, a claimant must be insured for disability insurance benefits. 42 U.S.C. § 423(a)(1)(a); 20 C.F.R. § 404.131. A. ADMINISTRATIVE REVIEW In evaluating whether a claimant is disabled, the “Social Security Administration, working through ALJs, decides whether a claimant is disabled by following a now familiar

five-step analysis.” Hess v. Comm’r Soc. Sec., 931 F.3d 198, 200–01 (3d Cir. 2019). The “burden of proof is on the claimant at all steps except step five, where the burden is on the Commissioner of Social Security.” Hess, 931 F.3d at 201; see 20 C.F.R. § 404.1512(a)(1). Thus, if the claimant establishes an inability to do past relevant work at step four, the burden shifts to the Commissioner at step five to show that jobs exist in significant numbers in the national economy that the claimant could perform consistent with his or her residual functional capacity, age, education, and past work experience. 20 C.F.R. § 404.1512(a)(1). B. JUDICIAL REVIEW The Court’s review of a determination denying an application for Title II benefits is limited “to considering whether the factual findings are supported by substantial evidence.”

Katz v. Comm’r Soc. Sec., No. 19-1268, 2019 WL 6998150, at *1 (3d Cir. Dec. 20, 2019). Substantial evidence “does not mean a large or considerable amount of evidence, but rather such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Pierce v. Underwood, 487 U.S. 552, 565 (1988) (internal quotation marks omitted). The quantum of proof is less than a preponderance of the evidence but more than a mere scintilla. Richardson v. Perales, 402 U.S. 389, 401 (1971). A single piece of evidence is not

“anatomical, physiological, or psychological abnormalities which are demonstrable by medically acceptable clinical and laboratory diagnostic techniques.” 42 U.S.C. § 423(d)(3). - 3 - substantial if the ALJ ignores countervailing evidence or fails to resolve a conflict created by such evidence. Mason v. Shalala, 994 F.2d 1058, 1064 (3d Cir. 1993). In an adequately developed factual record, substantial evidence may be “something less than the weight of the evidence, and the possibility of drawing two inconsistent conclusions from the evidence does

not prevent [the ALJ’s decision] from being supported by substantial evidence.” Consolo v. Fed. Maritime Comm’n, 383 U.S. 607, 620 (1966).

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