Baker v. Dudek

CourtDistrict Court, E.D. North Carolina
DecidedAugust 8, 2025
Docket7:24-cv-00553
StatusUnknown

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

Bluebook
Baker v. Dudek, (E.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA SOUTHERN DIVISION No. 7:24-CV-553-M-BM

MELISSA ROCHELLE BAKER, ) ) Plaintiff, ) ) v. ) MEMORANDUM AND ) RECOMMENDATION FRANK J. BISIGNANO, ) Commissioner of Social Security, ) ) Defendant. )

Plaintiff Melissa Rochelle Baker (“Plaintiff” or, in context, “Claimant”) filed this action pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3) seeking judicial review of the denial of her application for a period of disability and disability insurance benefits (“DIB”). This matter is before the court on Plaintiff’s brief [DE-8] (“Pl.’s brief”) seeking judgment in her favor, Defendant’s responsive brief [DE-10] (“Def.’s Brief”) in opposition, and Plaintiff’s reply brief [DE-11] (“Pl.’s Reply”). The parties have fully briefed this matter pursuant to the Supplemental Rules for Social Security Actions under 42 U.S.C. § 405(g), and this case is ripe for adjudication. The briefs were referred to the undersigned magistrate judge for a memorandum and recommendation pursuant to 28 U.S.C. § 636(b)(1). Having reviewed and considered the record, the administrative transcript, the briefs the parties submitted, and the applicable law, it is recommended that Plaintiff’s brief [DE-8] be ALLOWED, Defendant’s brief [DE-10] be DENED, and the decision of the Commissioner be REMANDED. I. STATEMENT OF THE CASE Plaintiff protectively filed an application for a period of disability and DIB on January 7, 2022, alleging disability beginning July 2, 2021. Transcript of Proceedings (“Tr.”) 96, 233-39. Her claim was denied initially. Tr. 88-96, 110-14. Plaintiff filed a request for reconsideration (Tr. 121) and was denied upon reconsideration on September 30, 2022 (Tr. 97-109, 122-26). On October 21, 2022, Plaintiff requested a hearing before the Administrative Law Judge (“ALJ”). Tr. 128-29. A hearing before the ALJ was held on May 1, 2023, at which Plaintiff, represented by an

attorney, and a vocational expert (“VE”) appeared and testified. Tr. 47-87. On August 11, 2023, the ALJ issued a decision denying Plaintiff’s request for benefits. Tr. 7-27. On September 26, 2023, Plaintiff requested a review of the ALJ’s decision by the Appeals Council. Tr. 230-32. On November 20, 2023, the Appeals Council denied Plaintiff’s request for review. Tr. 1-6. Plaintiff then filed a complaint in this court seeking appellate review of the now- final administrative decision. II. STANDARD OF REVIEW The scope of judicial review of a final agency decision regarding disability benefits under the Social Security Act (“Act”), 42 U.S.C. § 301 et seq., is limited to determining whether substantial evidence supports the Commissioner’s factual findings and whether the decision was

reached through the application of the correct legal standards. See Coffman v. Bowen, 829 F.2d 514, 517 (4th Cir. 1987). “The findings of the Commissioner . . . as to any fact, if supported by substantial evidence, shall be conclusive . . . .” 42 U.S.C. § 405(g). Substantial evidence is “evidence which a reasoning mind would accept as sufficient to support a particular conclusion.” Laws v. Celebrezze, 368 F.2d 640, 642 (4th Cir. 1966). While substantial evidence is not a “large or considerable amount of evidence,” Pierce v. Underwood, 487 U.S. 552, 565 (1988), it is “more than a mere scintilla . . . and somewhat less than a preponderance.” Laws, 368 F.2d at 642. “In reviewing for substantial evidence, [the court should not] undertake to re-weigh conflicting

2 evidence, make credibility determinations, or substitute [its] judgment for that of the [Commissioner].” Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001) (quoting Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996), superseded by regulation on other grounds, 20 C.F.R. § 416.927(d)(2)). Rather, in conducting the “substantial evidence” inquiry, the court’s review is

limited to whether the ALJ analyzed the relevant evidence and sufficiently explained his or her findings and rationale in crediting the evidence. Sterling Smokeless Coal Co. v. Akers, 131 F.3d 438, 439-40 (4th Cir. 1997). “Judicial review of an administrative decision is impossible without an adequate explanation of that decision by the administrator.” DeLoatche v. Heckler, 715 F.2d 148, 150 (4th Cir. 1983). III. DISABILITY EVALUATION PROCESS The disability determination is based on a five-step sequential evaluation process as set forth in 20 C.F.R. § 404.1520 under which the ALJ is to evaluate a claim: The claimant (1) must not be engaged in “substantial gainful activity [“SGA”],” i.e., currently working; and (2) must have a “severe” impairment that (3) meets or exceeds [in severity] the “listings” of specified impairments, or is otherwise incapacitating to the extent that the claimant does not possess the residual functional capacity [“RFC”] to (4) perform . . . past work or (5) any other work.

Albright v. Comm’r of the Soc. Sec. Admin., 174 F.3d 473, 475 n.2 (4th Cir. 1999). “If an applicant’s claim fails at any step of the process, the ALJ need not advance to the subsequent steps.” Pass v. Chater, 65 F.3d 1200, 1203 (4th Cir. 1995) (citation omitted). The burden of proof and production during the first four steps of the inquiry rests on the claimant. Id. At the fifth step, the burden shifts to the ALJ to show that other work exists in the national economy which the claimant can perform. Id. When assessing the severity of mental impairments, the ALJ must do so in accordance with

3 the “special technique” described in 20 C.F.R. §§ 404.1520a(b)-(c). This regulatory scheme identifies four broad functional areas in which the ALJ rates the degree of functional limitation resulting from a claimant’s mental impairment(s): understanding, remembering, or applying information; interacting with others; concentrating, persisting, or maintaining pace; and adapting

or managing oneself. Id. § 404.1520a(c)(3).

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Bluebook (online)
Baker v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/baker-v-dudek-nced-2025.