DENOI v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER

CourtDistrict Court, D. Maine
DecidedJune 12, 2023
Docket1:22-cv-00238
StatusUnknown

This text of DENOI v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER (DENOI v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER) is published on Counsel Stack Legal Research, covering District Court, D. Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
DENOI v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER, (D. Me. 2023).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MAINE

AARON D., ) ) Plaintiff ) ) v. ) 1:22-cv-00238-JAW ) KILO KIJAKAZI, Acting Commissioner ) of Social Security, ) ) Defendant )

REPORT AND RECOMMENDED DECISION

On Plaintiff’s application for disability insurance benefits under Title II and supplemental security income benefits under Title XVI of the Social Security Act, Defendant, the Social Security Administration Commissioner, found that Plaintiff has no severe impairments. Defendant, therefore, denied Plaintiff’s request for disability benefits. Plaintiff filed this action to obtain judicial review of Defendant’s final administrative decision pursuant to 42 U.S.C. § 405(g). Following a review of the record, and after consideration of the parties’ arguments, I recommend the Court vacate the administrative decision and remand the matter for further proceedings. THE ADMINISTRATIVE PROCEEDINGS AND FINDINGS On February 8, 2018, an ALJ found that Plaintiff had a severe impairment of the lumbar spine and limited him to light, simple work, with limited interaction with others. (R. 187-88, 190.) The ALJ denied Plaintiff’s disability claim, concluding that Plaintiff could perform other work available in the national economy. Plaintiff appealed from the ALJ’s decision. The Appeals Council vacated the decision and remanded the case for further administrative proceedings based on Plaintiff’s challenge to the ALJ’s authority under the Appointments Clause of the United States Constitution. (R. 203.) The Appeals

Council remanded the case to a different ALJ, noting that any defect in the appointment was cured by the remand because the then-Acting Commissioner had ratified all ALJ appointments and approved them as her own. (Id.) The Appeals Council ordered the new ALJ to provide Plaintiff “an opportunity for a hearing, address the evidence which was submitted with the request for review, take any further action needed to complete the

administrative record and issue a new decision.” (Id.) On remand, the ALJ found that Plaintiff did not have an impairment or combination of impairments that has significantly limited (or is expected to significantly limit) Plaintiff’s ability to perform basic work-related activities for twelve consecutive months. (R. 24.) The ALJ, therefore, found at step 2 that Plaintiff did not have a severe

impairment and thus was not disabled. (R. 28.) The Commissioner’s final decision is the August 2, 2021, decision of the Administrative Law Judge. (ALJ Decision, ECF No. 9-2).1 STANDARD OF REVIEW A court must affirm the administrative decision provided the decision is based on

the correct legal standards and is supported by substantial evidence, even if the record contains evidence capable of supporting an alternative outcome. Manso-Pizarro v. Sec’y

1 Because the Appeals Council found no reason to review that decision (R. 1.), Defendant’s final decision is the ALJ’s decision. of HHS, 76 F.3d 15, 16 (1st Cir. 1996) (per curiam); Rodriguez Pagan v. Sec’y of HHS, 819 F.2d 1, 3 (1st Cir. 1987). Substantial evidence is evidence that a reasonable mind might accept as adequate to support a finding. Richardson v. Perales, 402 U.S. 389, 401

(1971); Rodriguez v. Sec’y of HHS, 647 F.2d 218, 222 (1st Cir. 1981). “The ALJ’s findings of fact are conclusive when supported by substantial evidence, but they are not conclusive when derived by ignoring evidence, misapplying the law, or judging matters entrusted to experts.” Nguyen v. Chater, 172 F.3d 31, 35 (1st Cir. 1999). DISCUSSION

Plaintiff argues the ALJ erred when he failed to base his determination on the findings made by the prior ALJ in the previous decision. The authority Plaintiff cites is inapplicable here. Even if there are some circumstances that require a subsequent ALJ to adopt a prior ALJ’s findings on certain issues, no such circumstances exist in this case. Plaintiff essentially argues that the ALJ should adopt the findings of an ALJ whose

authority Plaintiff challenged. In its remand order, the Appeals Council cited Plaintiff’s challenge to the ALJ’s appointment and directed a different ALJ to conduct the review, which, in the Council’s view, would cure any appointment defect. If the ALJ were required to adopt the findings of the prior ALJ, the appointment defect, if any, would not be cured as the Appeals Council anticipated when it remanded the matter. The ALJ did

not err when he declined to adopt the findings of the prior ALJ. The issue generated by Plaintiff’s complaint is whether the ALJ erred when he determined that Plaintiff did not have a severe impairment. The ALJ found that Plaintiff had four medically determinable impairments: lumbar spine degenerative disc disease, obesity, anxiety disorder, and depressive disorder. He rejected Plaintiff’s fibromyalgia claim. At step 2 of the sequential evaluation process, a social security disability claimant

must establish the alleged conditions are severe, but the burden is de minimis and is designed merely to screen out groundless claims. McDonald v. Sec’y of HHS, 795 F.2d 1118, 1123-24 (1st Cir. 1986). The ALJ may find that an impairment or combination of impairments is not severe when the medical evidence “establishes only a slight abnormality or combination of slight abnormalities which would have no more than a

minimal effect on an individual’s ability to work even if the individual’s age, education, or work experience were specifically considered.” Id. at 1124 (quoting Social Security Ruling 85–28). In other words, an impairment is severe if it has more than a minimal impact on the claimant’s ability to perform basic work activities on a regular and continuing basis. Id. An impairment must meet the 12-month durational requirement to

be considered “severe.” 20 C.F.R. §§ 404.1509, 404.1520(a)(4)(ii), 416.909, 416.920(a)(4)(ii); Mulero v. Comm’r of Soc. Sec., 108 F. App’x 642, 644 (1st Cir. 2004) (to be severe, impairment must satisfy durational requirement). In concluding that Plaintiff’s back condition did not constitute a severe impairment, the ALJ relied principally on the July 30, 2016, consultative report of Jose

Rabelo, M.D., in which report Dr. Rabelo found Plaintiff’s degenerative disc disease to be non-severe. (R. 26.) Plaintiff contends the ALJ erred when he afforded great weight to Dr. Rabelo’s opinion largely because the opinion was inconsistent with the opinions Robert Phelps, M.D. offered before and after Dr. Rabelo’s opinion. “[A] DDS non-examining expert’s report cannot stand as substantial evidence in support of an administrative law judge’s decision when material new evidence has been submitted [that] call[s] the expert’s conclusions into question.” Eaton v. Astrue, Civil

No. 07-188-B-W, 2008 WL 4849327, at *5 (D. Me. Nov. 6, 2008). An ALJ may, however, rely on experts’ reports despite later-submitted evidence when the new evidence “does not call into question [the experts’] conclusions.” Emily A. v. Saul, No. 2:19-cv-00071-JDL, 2020 WL 2488576, at *7 (D. Me.

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DENOI v. SOCIAL SECURITY ADMINISTRATION COMMISSIONER, Counsel Stack Legal Research, https://law.counselstack.com/opinion/denoi-v-social-security-administration-commissioner-med-2023.