Brady v. Saul

CourtDistrict Court, M.D. Pennsylvania
DecidedNovember 8, 2021
Docket1:20-cv-00852
StatusUnknown

This text of Brady v. Saul (Brady 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
Brady v. Saul, (M.D. Pa. 2021).

Opinion

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

MARIE A. BRADY, : CIVIL NO.: 1:20-CV-00852 : Plaintiff, : : (Magistrate Judge Schwab) v. : : : KILOLO KIJAKAZI, Acting : Commissioner of Social Security, 1 : : Defendant. :

MEMORANDUM OPINION I. Introduction. This is a social security action brought under 42 U.S.C. § 1383(c)(3) (incorporating 42 U.SC. § 405(g)). The plaintiff, Marie A. Brady (“Brady”), seeks judicial review of the final decision of the Commissioner of Social Security (“Commissioner”) denying her claims for supplemental security income under

1 Kilolo Kijakazi is now the Acting Commissioner of Social Security, and she is automatically substituted as the Defendant in this action. See Fed. R. Civ. P. 25(d) (providing that when a public officer is sued in his or her official capacity ceases to hold office while the action is pending. “[t]he officer’s successor is automatically substituted as party”); 42. U.S.C. § 405(g) (“Any action instituted in accordance with this subsection shall survive notwithstanding any chance in the person occupying the office of Commissioner of Social Security or any vacancy in such office.”). Title XVI of the Social Security Act. For the reasons set forth below, we find that the Commissioner's decision is supported by substantial evidence, and accordingly

it will be affirmed.

II. Background and Procedural History.

We refer to the transcript provided by the Commissioner. See Doc. 10-1 through 10-7.2 On December 29, 2016, Brady applied for disability insurance benefits, alleging that she had been disabled since September 30, 2016. Admin. Tr. at 15. The Social Security Administration initially denied Brady’s claim on March

22, 2017. Id. Following the initial denial of Brady’s claim, the case went before the Administrative Law Judge Gerard W. Langan (the “ALJ”), who concluded that Brady, represented by counsel, was not disabled, and denied her benefits on that

basis in a written decision issued on March 12, 2019. Id. at 12-32. Brady requested a review of the ALJ's decision before the Social Security Administration's Appeals Council, but the Appeals Council denied her request for review on March 31, 2020. Id. at 1-6. Brady then filed a complaint with this court

on May 26, 2020, seeking judicial review of the Commissioner’s final decision to deny her benefits. Doc. 1. On November 4, 2020, the Commissioner filed an

2 The facts of the case are well known to the parties and will not be repeated here. Instead, we will recite only those facts that bear on Brady’s claim. answer to the complaint and a transcript of the proceedings that occurred before the Social Security Administration. Docs. 9-10. The parties have filed briefs, and this

matter is ripe for decision. Docs. 15, 18, 19.

III. Legal Standards. A. Substantial Evidence Review—the Role of This Court. When reviewing the Commissioner’s final decision denying a claimant’s

application for benefits, “the court has plenary review of all legal issues decided by the Commissioner.” Ficca v. Astrue, 901 F. Supp. 2d 533, 536 (M.D. Pa. 2012). But the court’s review of the Commissioner’s factual findings is limited to whether substantial evidence supports those findings. See 42 U.S.C. § 405(g); Biestek v.

Berryhill, 139 S. Ct. 1148, 1152 (2019). “[T]he threshold for such evidentiary sufficiency is not high.” Biestek, 139 S. Ct. at 1154. Substantial evidence “means—and means only—‘such relevant evidence as a reasonable mind might

accept as adequate to support a conclusion.’” Id. (quoting Consol. Edison Co. of New York v. N.L.R.B., 305 U.S. 197, 229 (1938)). Substantial evidence “is less than a preponderance of the evidence but more than a mere scintilla.” Jesurum v. Sec’y of U.S. Dep’t of Health & Human Servs.,

48 F.3d 114, 117 (3d Cir. 1995). A single piece of evidence is not substantial evidence if the ALJ ignores countervailing evidence or fails to resolve a conflict created by the evidence. Mason v. Shalala, 994 F.2d 1058, 1064 (3d Cir. 1993). But 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] finding from being supported by substantial evidence.” Consolo v. Fed. Maritime Comm’n, 383 U.S. 607, 620 (1966). “In determining if the Commissioner’s

decision is supported by substantial evidence the court must scrutinize the record as a whole.” Leslie v. Barnhart, 304 F. Supp. 2d 623, 627 (M.D. Pa. 2003). The question before this court, therefore, is not whether Brady is disabled, but whether substantial evidence supports the Commissioner’s finding that she is

not disabled and whether the Commissioner correctly applied the relevant law.

B. Initial Burdens of Proof, Persuasion, and Articulation. 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 work that exists in the national economy. 42 U.S.C. § 423(d)(2)(A) ; 20 C.F.R. § 404.1505(a).3

The ALJ follows a five-step sequential-evaluation process to determine whether a claimant is disabled. 20 C.F.R. § 404.1520(a). Under this process, the ALJ must sequentially determine: (1) whether the claimant is engaged in

substantial gainful activity; (2) whether the claimant has a severe impairment; (3) whether the claimant’s impairment meets or equals a listed impairment; (4) whether the claimant is able to do his or her past relevant work; and (5) whether the claimant is able to do any other work, considering his or her age,

education, work experience, and RFC. 20 C.F.R. § 404.1520(a)(4)(i)-(v). The ALJ must also assess a claimant’s RFC at step four. Hess v. Comm’r of Soc. Sec., 931 F.3d 198, 198 n.2 (3d Cir. 2019).

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Related

Consolo v. Federal Maritime Commission
383 U.S. 607 (Supreme Court, 1966)
Robert M. Wilson v. Commissioner of Social Security
378 F.3d 541 (Sixth Circuit, 2004)
Diaz v. Commissioner of Social Security
577 F.3d 500 (Third Circuit, 2009)
Johnson v. Commissioner of Social Security
529 F.3d 198 (Third Circuit, 2008)
Leslie v. Barnhart
304 F. Supp. 2d 623 (M.D. Pennsylvania, 2003)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Russell Hess, III v. Commissioner Social Security
931 F.3d 198 (Third Circuit, 2019)
Thomas v. Massanari
28 F. App'x 146 (Third Circuit, 2002)

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