Dunbar v. Commissioner of Social Security

CourtDistrict Court, M.D. Florida
DecidedSeptember 10, 2025
Docket5:25-cv-00457
StatusUnknown

This text of Dunbar v. Commissioner of Social Security (Dunbar v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, M.D. Florida primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Dunbar v. Commissioner of Social Security, (M.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF FLORIDA OCALA DIVISION

JOSEPH DUNBAR,

Plaintiff,

v. Case No: 5:25-cv-457-WFJ-PRL

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

ORDER Plaintiff Joseph Dunbar (“Plaintiff” or “Dunbar”), who is proceeding pro se, filed this action against the Commissioner of Social Security (the “Commissioner”), alleging that the Social Security Administration (“SSA”) has failed to pay Plaintiff’s benefits after an Administrative Law Judge (“ALJ”) issued a partially favorable decision, in which the ALJ found that Plaintiff was disabled beginning on January 1, 2023, but not before that date. (Doc. 1). Plaintiff seeks to proceed in forma pauperis. (Doc. 2). For the reasons explained below, Plaintiff’s Motion to Proceed in Forma Pauperis is taken under advisement, and in an abundance of caution, Plaintiff will be given an opportunity to amend the complaint. I. BACKGROUND Dunbar filed an application for supplemental security income (“SSI”) disability benefits on July 26, 2018. (Doc. 1 at pp. 5, 7). The ALJ issued a decision on Dunbar’s SSI claim on December 19, 2022, and Dunbar subsequently requested review of that decision by

the Appeals Council. (Id. at p. 14).1 On June 28, 2023, the Appeals Council granted Dunbar’s request, vacating the ALJ’s decision and remanding Dunbar’s case to the ALJ for resolution of the following issue: Subsequent to the hearing, on November 30, 2022, the Administrative Law Judge obtained 98 pages of evidence from Cardiology Partners dated May 19, 2021 to August 11, 2022 (Exhibit 27F). While the decision indicates this evidence was submitted by the claimant (Decision, page 1), the provider invoice (Not an exhibit), received into the electronic file on November 30, 2022, suggests otherwise. The Administrative Law Judge admitted the evidence into the record, but there is no indication that this evidence was proffered to the unrepresented claimant. Proffering evidence allows a claimant to comment on, object to, or refute the evidence by submitting other evidence (HALLEX2 1-2- 7-1 A). Pursuant to HALLEX 1-2-7-1 B, the Administrative Law Judge will proffer all post-hearing evidence unless the claimant or the appointed representative submitted it, the claimant knowingly waived the right to examine the evidence, or the decision is fully favorable to the claimant. None of these exceptions apply in this case.

(Id.). The Appeals Council’s order instructed the ALJ to offer Dunbar “an opportunity for a hearing, address the evidence which was submitted with [Dunbar’s] request for review, take

1 Plaintiff does not indicate what the outcomes were at the initial determination or reconsideration stages regarding his claim for SSI. 2 “HALLEX” is the Hearing, Appeals and Litigation Law Manual. It “provides guiding principles, procedural guidance and information to ALJs and staff at the Administration.” See McMurtry v. Astrue, 749 F. Supp. 2d 875, 880 (E.D. Wis. 2010) (citing Bowie v. Comm’r of Soc. Sec., 539 F.3d 395, 397 (6th Cir. 2008) and Moore v. Apfel, 216 F.3d 864, 868-69 (9th Cir. 2000)) (internal quotation marks omitted). any further action needed to complete the administrative record[,] and issue a new decision.” (Id. at p. 15).3 Following the Appeals Council remand order, the ALJ issued a partially favorable decision on March 22, 2024, finding that Dunbar was disabled beginning on January 1, 2023,

but not before then. (Id. at pp. 6-7).4 In that decision, the ALJ indicated that although Dunbar became disabled as of January 1, 2023, he advised Dunbar that “[a]nother office [within the SSA] will process [his] decision and decide if [he] meet[s] the non-disability requirements for [SSI] payments.” (Id. at p. 6). The ALJ further advised Dunbar that “[t]he component of the [SSA] responsible for authorizing supplemental security income will advise [Dunbar] regarding the non-disability requirements for these payments, and if eligible, the amount and the months for which payment will be made.” (Id. at p. 7). The ALJ’s decision further explained that if Dunbar disagreed with the decision, he could file an appeal with the Appeals Council. (Id. at p. 6). Dunbar does not allege that he sought review of the ALJ’s partially

favorable decision by the Appeals Council. (See generally id.). Dunbar initiated this action against the Commissioner on July 21, 2025, approximately 16 months after the ALJ issued the partially favorable decision, asserting that the SSA has failed to pay his benefits resulting from the ALJ’s decision. (Id. at pp. 2-3). In the complaint, Plaintiff alleges that the SSA has “targeted him through a pattern of intentional misconduct, delays[,] and denial of due process, despite . . . repeated notices and demands.” (Id. at p. 2). According to Plaintiff, he has been unsuccessful in his attempts to contact the

3 The Appeals Council also found no evidence supporting Dunbar’s allegation that the ALJ “targeted” him “by not giving him equal protection.” (Id.). 4 The Court notes that Plaintiff only included two pages from the ALJ’s decision issued on March 22, 2024, and not the entire decision with his complaint. (See id.). SSA concerning his case, as the SSA has failed to “respond to [his] formal demands or inquiries for over 15 months.” (Id. at p. 3). As a result of these alleged violations, Plaintiff asserts claims under the Mandamus Act, 28 U.S.C. § 1361; the Federal Tort Claims Act (“FTCA”), 28 U.S.C. § 1346(b); Bivens; 5 and alleges that his due process rights under the

Fifth Amendment had been violated by the SSA’s refusal to pay his benefits. (Id. at pp. 3-4). He asserts that the Court has jurisdiction over his claims pursuant to 42 U.S.C. § 405(g) of the Social Security Act; 28 U.S.C. § 1361 (mandamus); 28 U.S.C. § 1331 (federal question); 5 U.S.C. § 702 (Administrative Procedures Act); 28 U.S.C. § 1346(b) (FTCA); and the Fifth Amendment of the United States Constitution. (Id. at p. 1). Notably, while this action was pending, the SSA sent Dunbar a letter dated July 28, 2025, informing him that even though the ALJ found that he met the medical requirements as of January 1, 2023 to receive SSI, he was ineligible for SSI benefits because he did not meet the non-medical eligibility requirements. (Doc. 5 at p. 5). Specifically, the SSA determined

that Dunbar and his spouse had resources in excess of the $3,000 limit from multiple properties located at 22024 NW 242nd Street, Okeechobee, Florida; 21972 NW 242nd Street, Okeechobee, Florida; and 242nd Street, Okeechobee, Florida, totaling $28,125.00. (Id.). The letter provided Dunbar with the SSA’s basic rules for determining SSI eligibility, advising him that “[t]o be eligible for SSI, [the SSA] must determine that [he is] at least age 65, or that [he is] blind or disabled according to [its] rules. [He] must also meet certain requirements for . . . resources, and . . . [i]f [his] . . . resources are over the allowable limit, [he] cannot receive

5 See Bivens v. Six Unknown Named Agents of Fed. Bureau of Narcotics, 403 U.S. 388 (1971). SSI.” (Id.).

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Dunbar v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/dunbar-v-commissioner-of-social-security-flmd-2025.