Chavis v. Disability Determination Services

CourtDistrict Court, E.D. Virginia
DecidedMarch 14, 2025
Docket3:24-cv-00322
StatusUnknown

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

Bluebook
Chavis v. Disability Determination Services, (E.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division STEVEN C.,! ) ) Plaintiff, ) ) v. ) Civil No. 3:24-cv-322-MHL-SLS ) LELAND DUDEK,” ) Acting Commissioner of Social Security, ) ) Defendant. ) a) MEMORANDUM OPINION Plaintiff Steven C., proceeding pro se, filed this action challenging the Commissioner of the Social Security Administration’s (“SSA”) decision to deny his Title II application for disability insurance benefits. (ECF No. 3.) This matter comes before the Court on Defendant’s Motion to Dismiss or, in the alternative, for Summary Judgment (ECF Nos. 8, 9) and on Plaintiff's Motion for Summary Judgment (ECF No. 15). Defendant raises two arguments for dismissal of Plaintiff's claims. First, Defendant contends that the Commissioner of Social Security is the only proper defendant in a social security appeal. Because Plaintiff names only the Disability Determination Services, Defendant argues that Plaintiff's Complaint should be dismissed in its entirety for lack of jurisdiction under Rule 12(b)(1) of the Federal Rules of Civil Procedure. Second, Defendant argues that summary

! The Committee on Court Administration and Case Management of the Judicial Conference of the United States has recommended that federal courts refer to claimants by their first names and last initials in social security cases. ? Although the Complaint names the Disability Determination Services as Defendant in this action, the Court will order that Leland Dudek, the Acting Commissioner of Social Security, and the only proper defendant in a social security appeal, be substituted as Defendant and the Disability Determination Services be dismissed for the reasons stated below.

judgment should be granted in its favor under Rule 56 of the Federal Rules of Civil Procedure due to Plaintiff's failure to exhaust administrative remedies. Plaintiff also filed a Motion for Summary Judgment, asking that judgment be entered in his favor on the merits of his disability claim. (ECF No. 15.) Defendant opposes, arguing that Plaintiff's motion should be denied because “the Court lacks jurisdiction for want of the proper defendant” and because “Plaintiff has failed to exhaust his administrative remedies... .” (ECF No. 16, at 2.) The motions have been fully briefed (ECF Nos. 10, 13, 14, 15, 16), making them ripe for disposition. For the reasons articulated below, the Court will GRANT IN PART Defendant’s Motion to Dismiss for Lack of Jurisdiction. (ECF No. 8.) Specifically, the Court will DISMISS the Disability Determination Services from this action as an improper defendant, but instead of dismissing the action in its entirety on that basis, the Court will substitute the Commissioner as the proper defendant with respect to Plaintiffs claims. Further, the Court will GRANT Defendant’s Motion for Summary Judgment (ECF No. 9) and DISMISS WITHOUT PREJUDICE Plaintiff's claims based on Plaintiffs failure to exhaust administrative remedies. Because the Court will dismiss Plaintiff's claims based on his failure to exhaust administrative remedies, the Court will DENY Plaintiff's Motion for Summary Judgment. (ECF No. 15.) I. Standard of Review A. Rule 12(b)(1) Standard When a motion to dismiss challenges the Court’s subject matter jurisdiction, the burden rests with the plaintiff, as the party asserting jurisdiction, to prove that federal jurisdiction is proper. See Int'l Longshoremen’s Ass'n v. Va. Int’l Terminals, Inc., 914 F. Supp. 1335, 1338 (E.D. Va. Feb. 2, 1996) (citing McNutt v. Gen. Motors Acceptance Corp., 298 U.S. 178, 189

(1936); Adams v. Bain, 697 F.2d 1213, 1219 (4th Cir. 1982)). Where, as here, a motion to dismiss under Rule 12(b)(1) asserts that the complaint fails to state a claim upon which subject matter jurisdiction can lie, the Court assumes the truth of the facts alleged by Plaintiff. See id. (citing Adams, 697 F.2d at 1219). B. Rule 56 Standard Under Rule 56 of the Federal Rules of Civil Procedure, summary judgment is appropriate “if the movant shows that there is no genuine dispute as to any material fact and that the movant is entitled to judgment as a matter of law.” Fed. R. Civ. P. 56(a). A material fact is one that might affect the outcome of a party’s case. Anderson v. Liberty Lobby, Inc., 477 U.S. 242, 248 (1986); Hogan v. Beaumont, 779 F. App’x 164, 166 (4th Cir. 2019). A genuine issue concerning a material fact arises when the evidence is sufficient to allow a reasonable trier of fact to return a verdict in the party’s favor. Anderson, 477 U.S. at 248. The moving party has the initial burden of showing that no genuine issue of material fact exists. See Celotex Corp. v. Catrett, 477 U.S. 317, 324 (1986). The burden then shifts to the non-moving party to identify specific facts showing there is a genuine issue for trial. Id; Anderson, 477 U.S. at 248. The non-moving party must present some evidence other than conclusory or speculative allegations or a “mere scintilla of evidence” to survive summary judgment. Thompson v. Potomac Elec. Power Co., 312 F.3d 645, 649 (4th Cir. 2002). At the summary judgment stage, the Court views the facts presented by the evidence, and reasonable inferences therefrom, in the light most favorable to the non-moving party. United States v. 8.929 Acres of Land in Arlington Cnty., Virginia, 36 F.4th 240, 252 (4th Cir. 2022) (citing Carter v. Fleming, 879 F.3d 132, 139 (4th Cir. 2018)).

C. Standard for Pro Se Litigants Pleadings filed by pro se litigants should be afforded a liberal construction. Laber v. Harvey, 438 F.3d 404, 413 n.3 (4th Cir. 2006). The Court, however, need not attempt “to discern the unexpressed intent of the plaintiff.” Zd. Nor does the requirement of liberal construction excuse a clear failure in the pleading to allege a federally cognizable claim. See Weller v. Dep’t of Soc. Servs., 901 F.2d 387, 390-91 (4th Cir. 1990). Similarly, “appearing pro se does not relieve plaintiffs of the obligation to comply with the Federal Rules of Civil Procedure.” Spanos v. Vick, 576 F. Supp. 3d 361, 366 (E.D. Va. 2021). As the Fourth Circuit articulated in Beaudett v. City of Hampton, “[p]rinciples requiring generous construction of pro se complaints are not .. . without limits.” 775 F.2d 1274, 1278 (4th Cir. 1985).

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Related

McNutt v. General Motors Acceptance Corp.
298 U.S. 178 (Supreme Court, 1936)
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422 U.S. 749 (Supreme Court, 1975)
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466 U.S. 602 (Supreme Court, 1984)
Bowen v. City of New York
476 U.S. 467 (Supreme Court, 1986)
Anderson v. Liberty Lobby, Inc.
477 U.S. 242 (Supreme Court, 1986)
Adams v. Bain
697 F.2d 1213 (Fourth Circuit, 1982)
George F. Thompson v. Potomac Electric Power Company
312 F.3d 645 (Fourth Circuit, 2002)
Aaron Carter v. L. Fleming
879 F.3d 132 (Fourth Circuit, 2018)
Smith v. Berryhill
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Chavis v. Disability Determination Services, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chavis-v-disability-determination-services-vaed-2025.