AUSTIN v. DUDEK

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 26, 2025
Docket2:24-cv-02612
StatusUnknown

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

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AUSTIN v. DUDEK, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

JANE A., : CIVIL ACTION Plaintiff, : : vs. : NO. 24-cv-2612 : LELAND DUDEK, : Acting Commissioner of Social Security, : Defendant. :

MEMORANDUM OPINION

LYNNE A. SITARSKI UNITED STATES MAGISTRATE JUDGE March 26, 2025 Jane A. (“Plaintiff”) brought this action seeking review of the Commissioner of Social Security Administration’s (“SSA”) decision denying her claim for Social Security Disability Insurance under Title II of the Social Security Act, 42 U.S.C. §§ 401-433 (the “Act”). This matter is before me for disposition upon consent of the parties. For the reasons set forth below, Plaintiff’s Request for Review (ECF No. 14) is GRANTED.

I. PROCEDURAL HISTORY Plaintiff protectively filed the instant application for disability benefits1 on May 3, 2022, alleging disability beginning July 6, 2020, due to sleep apnea, gastroesophageal reflux disease (“GERD”), diabetes, high blood pressure, peripheral neuropathy, asthma, gastroparesis, non- alcoholic steatohepatitis (“NASH”), Meniere’s disease, left meniscal tear, obesity, hypertension,

1 Plaintiff previously filed an application for disability benefits on January 5, 2021, also alleging disability beginning on July 6, 2020. (R. 64). That application was ultimately denied on April 28, 2022, as a previous ALJ determined that Plaintiff was capable of performing light work with various limitations. (R. 61-83). liver disease, and degenerative disc or joint disease. (R. 14, 177-81). Plaintiff’s application was denied at the initial level on October 11, 2022. (R. 14, 84). Plaintiff then filed a request for reconsideration, which was denied on February 15, 2023. (R. 14, 95). Plaintiff requested a hearing before an Administrative Law Judge (“ALJ”). (R. 123-24). Plaintiff—represented by

counsel—as well as a vocational expert (“VE”) testified at the July 3, 2023, administrative hearing. (R. 29-60). At the hearing, Plaintiff amended the alleged onset date of her disability to April 29, 2022, the day after the denial of her prior application. (R. 33). On August 14, 2023, the ALJ issued a decision unfavorable to Plaintiff. (R. 11-28). Plaintiff appealed the ALJ’s decision, and the Appeals Council denied Plaintiff’s request for review on May 9, 2024, thus making the ALJ’s decision the final decision of the Commissioner for purposes of judicial review. (R. 1-6). On June 14, 2024, Plaintiff filed a complaint in the United States District Court for the Eastern District of Pennsylvania. (Compl., ECF No. 1). On July 9, 2024, Plaintiff consented to my jurisdiction pursuant to 28 U.S.C. § 636(c). (Consent, ECF No. 6). On October 24, 2024,

Plaintiff filed a Brief and Statement of Issues in Support of Request for Review. (Pl.’s Br., ECF No. 14). The Commissioner filed a Response on November 25, 2024. (Resp., ECF No. 15). Plaintiff filed a Reply on December 18, 2024. (Reply, ECF No. 18).

II. FACTUAL BACKGROUND The Court has considered the administrative record in its entirety and summarizes here the evidence relevant to the instant request for review. A. Medical Evidence Plaintiff has experienced gastrointestinal issues since at least 2017, when she was diagnosed with gastroparesis. She experiences nausea, headaches, dizziness, and several other symptoms characteristic of either Meniere’s disease or vestibular migraines.2 Plaintiff is also diagnosed with asthma, hypertriglyceridemia, sleep apnea, hypertension, type II diabetes, obesity, vascular disease, diabetic microangiopathy, metabolic syndrome, liver disease,

degenerative disc or joint disease, and a torn meniscus. (R. 91-92, 415-16, 456-57). To treat her diabetes, she takes metformin, Farxiga, and, since 2019, Ozempic. (R. 323, 489). On April 22, 2020, Plaintiff presented to her primary care provider, Alan Kravatz, M.D., of Penn Medicine, with breathing issues, lightheadedness, GERD, and pain in her bladder and right side. (R. 456-57). Upon examination, Dr. Kravatz noted that Plaintiff had epigastric tenderness and diagnosed her with shortness of breath; dyspepsia; generalized anxiety disorder; esophagitis; and abdominal pain, epigastric. (R. 458). At a December 15, 2020, evaluation, she reported pain in her left side and in her gallbladder, as well as having experienced diarrhea during the prior week. (R. 311). Dr. Kravatz noted mild upper abdominal tenderness. (Id.). His impressions were: “Essential hypertension, benign; Controlled type 2 diabetes mellitus without

complication, without long-term current use of insulin (CMS-HCC); Obstructive sleep apnea syndrome; Situational stress; Gastroesophageal reflux disease, unspecified whether esophagitis present.” (R. 312). On February 24. 2021, Plaintiff reported that she was still experiencing intermittent nausea due to gastroparesis. (R. 302, 990, 1240). At a May 25, 2021, follow-up appointment she reported that a recent increase of her Ozempic regimen had increased her nausea. (R. 433). On September 21, 2021, Plaintiff reported that she was still experiencing

2 A dispute exists in the medical record as to whether these symptoms are indicative of Meniere’s disease or vestibular migraines. Several medical providers have diagnosed Plaintiff with Meniere’s disease, (R. 323, 456), while others have disagreed with that diagnosis, instead diagnosing vestibular migraines. (R. 866, 1058). quick onset nausea and diarrhea “with urgency.” (R. 399-400). Plaintiff treated with Alan Schorr, D.O., of Penn Specialty Care Endocrinology located in Bucks County. On February 2, 2022, although Plaintiff reported intermittent nausea and vomiting, Dr. Schorr noted that Plaintiff’s abdomen was flat, no tenderness was present, her

bowel sounds were normal, and no distension was apparent. (R. 352-53). On May 18, 2022, Plaintiff again reported intermittent nausea and vomiting. (R. 332). Upon examination, Dr. Schorr noted that Plaintiff was “negative” for abdominal pain, blood in stool, constipation, diarrhea, heartburn, melena, dizziness, tingling, tremors, or headaches. (R. 332-33). Again, Plaintiff’s abdomen was flat, no tenderness was present, her bowel sounds were normal, and no distension was apparent. (R. 333). On September 21, 2022, Plaintiff noted continued intermittent gastrointestinal issues with chest discomfort, heartburn, nausea, and vomiting. (R. 1141). On September 27, 2022, Plaintiff complained of lightheadedness and dizziness. (R. 691). On June 20, 2023, Dr. Schorr noted that Plaintiff had fatigue, general malaise, muscle weakness, extremity pain and numbness, headaches, nausea and vomiting, and sensitivity to

light, heat, and cold. (R. 1523). He opined that she would frequently experience pain and other symptoms severe enough to interfere with her attention and concentration needed to perform simple work tasks. (R. 1524). He found that Plaintiff: was incapable of even “low stress” work; could sit 10 minutes before needing to get up and stand 10 minutes before needing to sit down; would need to walk for 10 minutes every 10 minutes; could sit, stand, and walk less than two hours each workday; required an at-will sit-stand option and unscheduled breaks twice a day for 15-20 minutes; needed to elevate her legs for 70% of the day; could rarely lift and carry 10 pounds; could rarely twist, stoop, and climb stairs and could never climb ladders; should avoid all exposure to extreme temperatures, humidity, wetness, smoke, perfume, fluxes, solvents, fumes, odors, gases, and chemicals and concentrated exposure to dust; and would miss more than four days of work per month. (R. 1524-25).

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AUSTIN v. DUDEK, Counsel Stack Legal Research, https://law.counselstack.com/opinion/austin-v-dudek-paed-2025.