Asiedu v. Commissioner of Social Security

CourtDistrict Court, S.D. New York
DecidedJuly 12, 2023
Docket1:22-cv-01353
StatusUnknown

This text of Asiedu v. Commissioner of Social Security (Asiedu v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Asiedu v. Commissioner of Social Security, (S.D.N.Y. 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ----------------------------------------------------- DAVID A.,

Plaintiff, DECISION AND ORDER 1:22-cv-01353-GRJ v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant. ----------------------------------------------------- GARY R. JONES, United States Magistrate Judge:

In November of 2019, Plaintiff David A.1 applied for Supplemental Security Income benefits under the Social Security Act. The Commissioner of Social Security denied the application. Plaintiff, represented by Ny Disability, LLC, Daniel Berger, Esq., of counsel, commenced this action seeking judicial review of the Commissioner’s denial of benefits under 42 U.S.C. §§ 405 (g) and 1383 (c)(3). The parties consented to the jurisdiction of a United States Magistrate Judge. (Docket No. 14). This case was referred to the undersigned on March 17, 2023. Presently pending are the parties’ Motions for Judgment on the Pleadings under Rule 12 (c) of the Federal Rules of Civil Procedure. (Docket Nos. 21,

1 Plaintiff’s name has been partially redacted in compliance with Federal Rule of Civil Procedure 5.2 (c)(2)(B) and the recommendation of the Committee on Court Administration and Case Management of the Judicial Conference of the United States. 23). For the following reasons, Plaintiff’s motion is due to be granted, the Commissioner’s motion is due to be denied, and this case is remanded for

further administrative proceedings. I. BACKGROUND A. Administrative Proceedings

Plaintiff applied for benefits on November 4, 2019, alleging disability beginning July 1, 2018. (T at 27, 97, 110).2 Plaintiff’s application was denied initially and on reconsideration. He requested a hearing before an Administrative Law Judge (“ALJ”). A hearing was held on October 19,

2020, before ALJ Selwayn Walters. (T at 59-86). Plaintiff appeared with an attorney and testified. (T at 65-81). The ALJ also received testimony from Michael Dorval, a vocational expert. (T at 83-85).

B. ALJ’s Decision On March 26, 2021, the ALJ issued a decision denying the application for benefits. (T at 24-41). The ALJ found that Plaintiff had not engaged in substantial gainful activity since November 4, 2019 (the alleged

onset date). (T at 29). The ALJ concluded that Plaintiff’s seizure disorder was a severe impairment as defined under the Social Security Act. (T at 29).

2 Citations to “T” refer to the administrative record transcript at Docket No. 11. However, the ALJ found that Plaintiff did not have an impairment or combination of impairments that met or medically equaled one of the listed

impairments in 20 CFR Part 403, Subpart P, Appendix 1. (T at 31). At step four of the sequential analysis the ALJ determined that Plaintiff retained the residual functional capacity (“RFC”) to perform a full

range of work at all exertional levels, with the following non-exertional limitations: he cannot climb ladders, ropes, or scaffolds and must avoid unprotected heights, moving mechanical parts, and the operation of heavy machinery and motor vehicles. (T at 32).

The ALJ found that Plaintiff had no past relevant work (T at 35). Considering Plaintiff’s age (35 on the application date), education (limited), work experience, and RFC, the ALJ determined that there are jobs that

exist in significant numbers in the national economy that Plaintiff can perform. (T at 36). As such, the ALJ found that Plaintiff had not been under a disability, as defined under the Social Security Act, and was not entitled to benefits

for the period between November 9, 2019 (the application date) and March 26, 2021 (the date of the ALJ’s decision). (T at 37. On January 26, 2022, the Appeals Council denied Plaintiff’s request for review, making the ALJ’s

decision the Commissioner’s final decision. (T at 1-7). C. Procedural History Plaintiff commenced this action, by and through his counsel, by filing

a Complaint on February 17, 2022. (Docket No. 1). On January 24, 2023, Plaintiff filed a motion for judgment on the pleadings, supported by a memorandum of law. (Docket No. 21, 22). The Commissioner interposed a

cross-motion for judgment on the pleadings, supported by a memorandum of law, on March 15, 2023. (Docket No. 23, 24). On April 17, 2023, Plaintiff submitted a reply memorandum of law in further support of his motion. (Docket No. 25).

II. APPLICABLE LAW A. Standard of Review “It is not the function of a reviewing court to decide de novo whether a

claimant was disabled.” Melville v. Apfel, 198 F.3d 45, 52 (2d Cir. 1999). The court’s review is limited to “determin[ing] whether there is substantial evidence supporting the Commissioner's decision and whether the Commissioner applied the correct legal standard.” Poupore v. Astrue, 566

F.3d 303, 305 (2d Cir. 2009) (per curiam). The reviewing court defers to the Commissioner's factual findings, which are considered conclusive if supported by substantial evidence. See

42 U.S.C. § 405(g). “Substantial evidence” is “more than a mere scintilla” and “means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Lamay v. Commissioner of Soc. Sec.,

562 F.3d 503, 507 (2d Cir. 2009) (internal quotations omitted) (quoting Richardson v. Perales, 402 U.S. 389, 401 (1971)). “In determining whether the agency's findings are supported by

substantial evidence, the reviewing court is required to examine the entire record, including contradictory evidence and evidence from which conflicting inferences can be drawn.” Talavera v. Astrue, 697 F.3d 145, 151 (2d Cir. 2012) (internal quotations omitted).

“When there are gaps in the administrative record or the ALJ has applied an improper legal standard,” or when the ALJ’s rationale is unclear, remand “for further development of the evidence” or for an explanation of

the ALJ’s reasoning is warranted. Pratts v. Chater, 94 F.3d 34, 39 (2d Cir. 1996). B. Five-Step Sequential Evaluation Process Under the Social Security Act, a claimant is disabled if he or she

lacks the ability “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).

A claimant’s eligibility for disability benefits is evaluated pursuant to a five-step sequential analysis: 1. The Commissioner considers whether the claimant is currently engaged in substantial gainful activity.

2. If not, the Commissioner considers whether the claimant has a “severe impairment” which limits his or her mental or physical ability to do basic work activities.

3.

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