Blackstock v. Dudek

CourtDistrict Court, W.D. Virginia
DecidedMarch 31, 2025
Docket4:23-cv-00022
StatusUnknown

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

Bluebook
Blackstock v. Dudek, (W.D. Va. 2025).

Opinion

Rowe VA 3/31/2025 LAURAA. . AUSTIN, CLERK IN THE UNITED STATES DISTRICT COURT DEPUTY CLERK FOR THE WESTERN DISTRICT OF VIRGINIA DANVILLE DIVISION TANAYSIA B., ) ) Plaintiff, ) Civil Action No. 4:23-cv-00022 ) v. ) MEMORANDUM OPINION ) LELAND DUDEK, ) By: | Hon. Thomas T. Cullen Commissioner of Social Security, ) United States District Judge ) Defendant. )

Plaintiff Tanaysia B. (“Tanaysia’’) filed suit in this court seeking review of the Commissioner of Social Security’s (‘Commissioner’) final decision denying her claim for Supplemental Security Income (“SSI”) under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381-1385.! Tanaysia suffers primarily from ADHD, obesity, some muscle weakness, and coordination issues. On review of her application for SSI, an administrative law judge (“ALJ”) concluded that Tanaysia did not have an impairment or combination of impairments that functionally equals any listing based on the six functional equivalence domains. She challenges that conclusion, calling for reversal and summary judgment in her favor on the grounds that the ALJ’s opinion is not supported by substantial evidence in multiple respects. After a thorough review of the record and the ALJ’s opinion, the court concludes that the AL] failed to adequately explain his reasoning regarding the determinations of the functional equivalence

' Leland Dudek became the Acting Commissioner of Social Security on February 16, 2025. Under Rule 25(d) of the Federal Rules of Crvil Procedure, Leland Dudek is substituted for Martin O’Malley as the defendant in this suit. See a/so 42 U.S.C. § 405(g) (Any action instituted in accordance with this subsection shall survive notwithstanding any change in the person occupying the office of the Commissioner of Social Security or any vacancy in such office.”).

domains. Accordingly, because these analytical omissions frustrate the court’s review, the court will remand this case to the Commissioner for further administrative proceedings consistent with this opinion.

I. STANDARD OF REVIEW A. Commissioner’s Decision The Social Security Act (the “Act”) authorizes this court to review the Commissioner’s final decision that a person is not entitled to social security benefits. 42 U.S.C. § 405(g); see also Hines v. Barnhart, 453 F.3d 559, 561 (4th Cir. 2006). The court’s role, however, is limited; it may not “reweigh conflicting evidence, make credibility determinations, or substitute [its]

judgment” for that of agency officials. Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012) (internal quotation omitted). Instead, in reviewing the merits of the Commissioner’s final decision, a court asks only whether the ALJ applied the correct legal standards and whether “substantial evidence” supports the ALJ’s factual findings. Meyer v. Astrue, 662 F.3d 700, 704 (4th Cir. 2011); see Riley v. Apfel, 88 F. Supp. 2d 572, 576 (W.D. Va. 2000). In this context, “substantial evidence” means “such relevant evidence as a reasonable

mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971) (internal quotation omitted). It is “more than a mere scintilla” of evidence, id., but not necessarily “a large or considerable amount of evidence,” Pierce v. Underwood, 487 U.S. 552, 565 (1988). Substantial evidence review considers the entire record, and not just the evidence cited by the ALJ. See Universal Camera Corp. v. NLRB, 340 U.S. 474, 487–89 (1951); Gordon v. Schweiker, 725 F.2d 231, 236 (4th Cir. 1984). Ultimately, this court must affirm the ALJ’s factual

findings if “conflicting evidence allows reasonable minds to differ as to whether a claimant is disabled.” Johnson v. Barnhart, 434 F.3d 650, 653 (4th Cir. 2005) (per curiam) (internal quotation omitted). But “[a] factual finding by the ALJ is not binding if it was reached by means of an improper standard or misapplication of the law.” Coffman v. Bowen, 829 F.2d 514, 517 (4th Cir.

1987). Generally, a reviewing court will affirm the ALJ’s findings when he has considered all the relevant evidence under the correct legal standards, and the written decision has built “an accurate and logical bridge from the evidence to [his] conclusions.’” Arakas v. Comm’r. Soc. Sec. Admin., 983 F.3d 83, 95 (4th Cir. 2020) (citing Monroe v. Colvin, 826 F.3d 176, 189 (4th Cir. 2016) (internal quotation omitted). B. Childhood Disability Claims

A person under the age of eighteen is “disabled,” as that term is defined by the Act, if she “has a medically determinable physical or mental impairment, which results in marked and severe functional limitations, and 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. § 1382c(a)(3)(C)(i). ALJs follow a three-step process to determine whether a child applicant is disabled. The ALJ asks, in sequence, whether the applicant: (1) is engaged in substantial gainful

activity; (2) has a severe medically determinable impairment; and (3) has an impairment or combination of impairments that meets, medically equals, or functionally equals the presumptively disabling childhood impairments listed in the Act’s regulations. Bryant v. Barnhart, 63 F. App’x 90, 92–93 (4th Cir. 2003); 20 C.F.R. § 416.924(a). If the ALJ finds that the applicant’s severe impairment or combination of impairments does not meet or medically equal a specific listed impairment, then the ALJ must evaluate how

appropriately, effectively, and independently the applicant functions in “six domains” when compared to other children the same age “who do not have impairments.” 20 C.F.R. § 416.926a. The six domains are: (1) acquiring and using information; (2) attending and completing tasks; (3) interacting and relating with others; (4) moving about and manipulating

objects; (5) caring for oneself; and (6) health and physical well-being. Id. To functionally equal the listings, the applicant’s severe impairment or combination of impairments must cause “marked limitations” in two domains or an “extreme limitation” in one domain.2 The applicant bears the burden of proving that she is disabled. S.R. ex rel. R.R. v. Barnhart, 371 F. Supp. 2d 796, 799 (W.D. Va. 2005).

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Meyer v. Astrue
662 F.3d 700 (Fourth Circuit, 2011)
Bryant Ex Rel. Bryant v. Barnhart
63 F. App'x 90 (Fourth Circuit, 2003)
Jimmy Radford v. Carolyn Colvin
734 F.3d 288 (Fourth Circuit, 2013)
Riley v. Apfel
88 F. Supp. 2d 572 (W.D. Virginia, 2000)
George Monroe v. Carolyn Colvin
826 F.3d 176 (Fourth Circuit, 2016)
Nikki Thomas v. Nancy Berryhill
916 F.3d 307 (Fourth Circuit, 2019)
Hancock v. Astrue
667 F.3d 470 (Fourth Circuit, 2012)
S.R. ex rel. R.R. v. Barnhart
371 F. Supp. 2d 796 (W.D. Virginia, 2005)
Coffman v. Bowen
829 F.2d 514 (Fourth Circuit, 1987)

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Blackstock v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/blackstock-v-dudek-vawd-2025.