Charlene C. v. Dudek

CourtDistrict Court, D. Rhode Island
DecidedFebruary 24, 2025
Docket1:24-cv-00354
StatusUnknown

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

Bluebook
Charlene C. v. Dudek, (D.R.I. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF RHODE ISLAND

CHARLENE C. : : v. : C.A. No. 24-00354-MSM : LELAND C. DUDEK, Acting : Commissioner : Social Security Administration :

REPORT AND RECOMMENDATION

Lincoln D. Almond, United States Magistrate Judge

This matter is before the Court for judicial review of a final decision of the Commissioner of the Social Security Administration (“Commissioner”) denying Disability Insurance Benefits (“DIB”) under the Social Security Act (the “Act”), 42 U.S.C. § 405(g). Plaintiff filed her Complaint on September 3, 2024, seeking to reverse the Decision of the Commissioner. On January 10, 2025, Plaintiff filed a Motion to Reverse the Decision of the Commissioner. (ECF No. 8). On February 3, 2025, Defendant filed a Motion for an Order Affirming the Decision of the Commissioner. (ECF No. 9). No reply brief was filed. This matter has been referred to me for preliminary review, findings, and recommended disposition. 28 U.S.C. § 636(b)(1)(B); LR Cv 72. Based upon my review of the record, the parties’ submissions, and independent research, I find that there is not substantial evidence in this record to support the Commissioner’s decision and findings that Plaintiff is not disabled within the meaning of the Act. Consequently, I recommend that Plaintiff’s Motion to Reverse (ECF No. 8) be GRANTED and that the Commissioner’s Motion for an Order Affirming (ECF No. 9) be DENIED. I. PROCEDURAL HISTORY Plaintiff filed an application for DIB on September 30, 2021. (Tr. 187-188). The application was denied initially on February 9, 2022 (Tr. 62-70) and on reconsideration on March 30, 2022. (Tr. 72-79). Plaintiff requested an Administrative Hearing which was held on March 2, 2023 before Administrative Law Judge Tracy LaChance (the “ALJ”). Plaintiff, represented by counsel, and a Vocational Expert (“VE”) appeared and testified. (Tr. 37-60). The ALJ issued an

unfavorable decision to Plaintiff on October 19, 2023. (Tr. 19-31). The Appeals Council denied Plaintiff’s request for review on June 28, 2024. (Tr. 6-8). Therefore, the ALJ’s decision became final. A timely appeal was then filed with this Court. II. THE PARTIES’ POSITIONS

Plaintiff argues that the ALJ erred by failing to pose any hypothetical questions to the VE, by failing to properly evaluate an opinion from her treating psychiatrist, and by “mis-analyzing” medical evidence. The Commissioner disputes Plaintiff’s claims of error and argues that affirmance is warranted. III. THE STANDARD OF REVIEW

The Commissioner’s findings of fact are conclusive if supported by substantial evidence. 42 U.S.C. § 405(g). Substantial evidence is more than a scintilla – i.e., the evidence must do more than merely create a suspicion of the existence of a fact and must include such relevant evidence as a reasonable person would accept as adequate to support the conclusion. Ortiz v. Sec’y of HHS, 955 F.2d 765, 769 (1st Cir. 1991) (per curiam); Rodriguez v. Sec’y of HHS, 647 F.2d 218, 222 (1st Cir. 1981). Where the Commissioner’s decision is supported by substantial evidence, the court must affirm, even if the court would have reached a contrary result as finder of fact. Rodriguez Pagan v. Sec’y of HHS, 819 F.2d 1, 3 (1st Cir. 1987); Barnes v. Sullivan, 932 F.2d 1356, 1358 (11th Cir. 1991). The court must view the evidence as a whole, taking into account evidence favorable as well as unfavorable to the decision. Frustaglia v. Sec’y of HHS, 829 F.2d 192, 195 (1st Cir. 1987); Parker v. Bowen, 793 F.2d 1177 (11th Cir. 1986) (court also must consider evidence detracting

from evidence on which Commissioner relied). The court must reverse the ALJ’s decision on plenary review, however, if the ALJ applies incorrect law, or if the ALJ fails to provide the court with sufficient reasoning to determine that he or she properly applied the law. Nguyen v. Chater, 172 F.3d 31, 35 (1st Cir. 1999) (per curiam); accord Cornelius v. Sullivan, 936 F.2d 1143, 1145 (11th Cir. 1991). Remand is unnecessary where all of the essential evidence was before the Appeals Council when it denied review, and the evidence establishes without any doubt that the claimant was disabled. Seavey v. Barnhart, 276 F.3d 1, 11 (1st Cir. 2001) citing, Mowery v. Heckler, 771 F.2d 966, 973 (6th Cir. 1985).

The court may remand a case to the Commissioner for a rehearing under sentence four of 42 U.S.C. § 405(g); under sentence six of 42 U.S.C. § 405(g); or under both sentences. Seavey, 276 F.3d at 8. To remand under sentence four, the court must either find that the Commissioner’s decision is not supported by substantial evidence, or that the Commissioner incorrectly applied the law relevant to the disability claim. Id.; accord Brenem v. Harris, 621 F.2d 688, 690 (5th Cir. 1980) (remand appropriate where record was insufficient to affirm, but also was insufficient for district court to find claimant disabled). Where the court cannot discern the basis for the Commissioner’s decision, a sentence-four

remand may be appropriate to allow her to explain the basis for her decision. Freeman v. Barnhart, 274 F.3d 606, 609-610 (1st Cir. 2001). On remand under sentence four, the ALJ should review the case on a complete record, including any new material evidence. Diorio v. Heckler, 721 F.2d 726, 729 (11th Cir. 1983) (necessary for ALJ on remand to consider psychiatric report tendered to Appeals Council). After a sentence four remand, the court enters a final and appealable judgment immediately, and thus loses jurisdiction. Freeman, 274 F.3d at 610. In contrast, sentence six of 42 U.S.C. § 405(g) provides:

The court...may at any time order additional evidence to be taken before the Commissioner of Social Security, but only upon a showing that there is new evidence which is material and that there is good cause for the failure to incorporate such evidence into the record in a prior proceeding;

42 U.S.C. § 405(g).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Heckler v. Campbell
461 U.S. 458 (Supreme Court, 1983)
Seavey v. Social Security
276 F.3d 1 (First Circuit, 2001)
Freeman v. Massanari
274 F.3d 606 (First Circuit, 2001)

Cite This Page — Counsel Stack

Bluebook (online)
Charlene C. v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/charlene-c-v-dudek-rid-2025.