Burd v. O'Malley

CourtDistrict Court, M.D. Pennsylvania
DecidedFebruary 24, 2025
Docket3:24-cv-00197
StatusUnknown

This text of Burd v. O'Malley (Burd v. O'Malley) 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
Burd v. O'Malley, (M.D. Pa. 2025).

Opinion

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

DOUGLAS A. BURD, : Civil No. 3:24-CV-00197 : Plaintiff, : : v. : : LELAND DUDEK,1 : (Magistrate Judge Carlson) Acting Commissioner of Social Security, : : Defendant. :

MEMORANDUM OPINION

I. Introduction The plaintiff in this social security appeal, Douglas Burd, is a military veteran and previously worked in IT at a computer help desk. In November 2021, following two emotional outbursts at his job, Burd took a leave of absence and subsequently filed applications for disability and supplemental security benefits. He alleges he is unable to work due an array of psychological impairments including intermittent explosive disorder (IED), posttraumatic stress disorder (PTSD), attention deficit

1Leland Dudek became the Acting Commissioner of Social Security on February 16, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Leland Dudek should be substituted for the previously named defendant in this suit. No further action need be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g).

1 disorder (ADD), anxiety, bipolar disorder, borderline personality disorder, and depression. Despite his statements regarding the limiting effects of these

impairments on his ability to work, the clinical record of his treatment is limited, showing only that he was receiving medication management and supportive therapy every three weeks. He also appeared to be relatively independent in his activities of

daily living and two state agency medical consultants opined that Burd had only mild to moderate limitations in each area of mental functioning. Upon this limited and unremarkable record, on January 23, 2023, an administrative law judge (ALJ) concluded that Burd had not met the rigorous standards to

demonstrate he was precluded from performing work-related activities under the Social Security Act and denied his claim. This appeal followed. On appeal, Burd challenges the ALJ’s decision, arguing

that the ALJ’s residual functional capacity assessment lacks evidentiary support, that the ALJ failed to properly evaluate the opinions of Burd’s treating psychiatric providers, and that the ALJ erred in the symptom evaluation in this case. In considering these arguments advanced by the plaintiff, we recognize a legal truth:

the Supreme Court has underscored for us the limited scope of our substantive review when examining Social Security appeals, noting that:

2 The phrase “substantial evidence” is a “term of art” used throughout administrative law to describe how courts are to review agency factfinding. T-Mobile South, LLC v. Roswell, 574 U.S. ––––, ––––, 135 S. Ct. 808, 815, 190 L.Ed.2d 679 (2015). Under the substantial- evidence standard, a court looks to an existing administrative record and asks whether it contains “sufficien[t] evidence” to support the agency’s factual determinations. Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S. Ct. 206, 83 L.Ed. 126 (1938) (emphasis deleted). And whatever the meaning of “substantial” in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence, this Court has said, is “more than a mere scintilla.” Ibid.; see, e.g., Perales, 402 U.S. at 401, 91 S. Ct. 1420 (internal quotation marks omitted). It means—and means only—“such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Consolidated Edison, 305 U.S. at 229, 59 S. Ct. 206. See Dickinson v. Zurko, 527 U.S. 150, 153, 119 S. Ct. 1816, 144 L.Ed.2d 143 (1999) (comparing the substantial-evidence standard to the deferential clearly- erroneous standard). Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019). In this case, after a review of the record, and mindful of the fact that substantial evidence “means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion,’” Biestek, 139 S. Ct. at 1154, we find that substantial evidence supported the ALJ’s findings in this case. Therefore, for the reasons set forth below, we recommend that the Court affirm the decision of the Commissioner denying this claim.

3 II. Statement of Facts and of the Case

On November 4, 2021, the plaintiff, Douglas Burd, protectively filed an application for disability and disability insurance benefits under Title II and an application for supplemental security income under Title XVI of the Social Security Act, alleging an onset of his disability on November 12, 2021, due to a series of

mental impairments including attention deficit disorder (ADD), anxiety, bipolar disorder, borderline personality disorder, depression, intermittent explosive disorder (IED), posttraumatic stress disorder (PTSD), sleep apnea, involuntary movements, and memory loss. (Tr. 14, 56). His claim was considered by an administrative law

judge (ALJ) and, following a hearing, the ALJ concluded in a January 23, 2023, decision that Burd’s conditions were not completely disabling under the rigorous standards which govern disability claims. (Tr. 11-29).

A. The Medical Record and Burd’s Activities of Daily Living The record demonstrates that Burd suffered from several nonsevere physical impairments, including obesity, obstructive sleep apnea, and tremors, but his severe impairments were psychological in nature. On this score, the primary reason Burd

cites for his inability to engage in sustained work-related activity is his difficulty interacting with others related to his bipolar and intermittent explosive disorder. In fact, the alleged date of onset of his disability in November 2021 coincides with a

4 second reported “outburst” at his job, where he was reported for yelling in the parking lot of his workplace after his car was repossessed, after which time he took

a leave of absence. (Tr. 376). But, despite this reported outburst, along with another incident in which he yelled at his bosses and was written up, his leave of absence was voluntary, and he reported that he was never fired or laid off from a job because

of problems getting along with other people. (Tr. 301). With respect to his mental impairments, the clinical record for the pertinent period revealed that Burd was being treated by VA Medical Services, receiving psychiatric medication management and attending supportive therapy with a social

worker every three weeks between November 2021 and October 2022. (Tr. 347- 573). In his therapy sessions, Burd consistently reported stable mood, with occasional irritability, anxiety, and sleep difficulties, and his mental status

examinations were always unremarkable, including good attitude, calm affect, stable mood, intact thought process/content, fully oriented average insight/judgment, intellectual/cognitive functioning within normal limits. (Id.) At his initial evaluation for supportive therapy with social worker Luther

Brice at VA Medical Services, Burd reported that he was seeking treatment for help dealing with bipolar disorder and would like to feel happier and less stressed. (Tr. 384-85). He reported one psychiatric hospitalization, though no details are provided,

5 and indicated he used medical marijuana but reported completely independent activities of daily living, including the ability to maintain a residence and do

household chores. (Tr. 386).

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Consolo v. Federal Maritime Commission
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Richardson v. Perales
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Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Dickinson v. Zurko
527 U.S. 150 (Supreme Court, 1999)
Kacee Chandler v. Commissioner Social Security
667 F.3d 356 (Third Circuit, 2011)

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Burd v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/burd-v-omalley-pamd-2025.