Durant v. Commissioner of Social Security Administration

CourtDistrict Court, W.D. Virginia
DecidedJuly 30, 2025
Docket6:24-cv-00030
StatusUnknown

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

Bluebook
Durant v. Commissioner of Social Security Administration, (W.D. Va. 2025).

Opinion

AT LYNCHBURG, VA FILED IN THE UNITED STATES DISTRICT COURT 7/30/2025 FOR THE WESTERN DISTRICT OF VIRGINIA LAURA A. AUSTIN, CLERK LYNCHBURG DIVISION BY; §/ ARLENPAUTTLE DEPUTY CLERK JOYCE D.,1 ) ) Civil Action No. 6:24-cv-00030 Plaintiff, ) ) REPORT & Vv. ) RECOMMENDATION ) FRANK J. BISIGNANO,?2 ) By: C. Kailani Memmer Commissioner of Social Security, ) United States Magistrate Judge ) Defendant. )

Plaintiff Joyce D. (“Joyce”) filed this action challenging the final decision of the Commissioner of Social Security (“Commissioner”) finding her not disabled and therefore ineligible for Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”) under the Social Security Act (“Act”). 42 U.S.C. §§ 401-433; 42 U.S.C. 88 1381- 1383f. Joyce alleges that Administrative Law Judge Eric Eklund (“ALJ”) erred by (1) failing to sufficiently explain the how he reconciled a moderate restriction in concentration, persistence and pace with his omission of corresponding limitations in her residual functional capacity (“RFC”) determination and (2) assessing her subjective allegations of physical impairments. (See ECF No. 12.) Having considered the administrative record, the parties’ filings, and the applicable law, I respectfully recommend the presiding District Judge REMAND the Commissioner’s final decision for further consideration.

1 Due to privacy concerns, I use only the first name and last initial of the claimant in social security opinions. 2 Frank J. Bisignano became the Acting Commissioner of Social Security on May 7, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Frank J. Bisignano should be substituted for Martin O’Malley as the 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).

STANDARD OF REVIEW The court limits its review to a determination of whether substantial evidence exists to support the Commissioner’s conclusion that Joyce failed to demonstrate that she was disabled under the Act.3 Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001). “Substantial evidence is such relevant evidence as a reasonable mind might accept as

adequate to support a conclusion; it consists of more than a mere scintilla of evidence but may be somewhat less than a preponderance.” Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996) (citation modified); see also Biestek v. Berryhill, 587 U.S. 97, 139 (2019) (emphasizing that the standard for substantial evidence “is not high”). While substantial evidence is a somewhat deferential standard, the Court does not “reflexively rubber- stamp an ALJ’s findings.” Lewis v. Berryhill, 858 F.3d 858, 870 (4th Cir. 2017). “In reviewing for substantial evidence, [the court should not] undertake to re- weigh conflicting evidence, make credibility determinations, or substitute [its] judgment for that of the [Commissioner].” Mastro, 270 F.3d at 176 (quoting Craig, 76 F.3d at 589). Nevertheless, the court “must not abdicate [its] traditional functions,” and it “cannot escape [its] duty to scrutinize the record as a whole to determine whether the conclusions

reached are rational.” Oppenheim v. Finch, 495 F.2d 396, 397 (4th Cir. 1974). The final decision of the Commissioner will be affirmed where substantial evidence supports the decision. Hays v. Sullivan, 907 F.2d 1453, 1456 (4th Cir. 1990).

3 The Act defines “disability” as the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment, which can be expected to result in death or which has lasted or can be expected to last for a continuous period for not less than 12 months.” 42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). Disability under the Act requires showing more than the fact that the claimant suffers from an impairment which affects his ability to perform daily activities or certain forms of work; instead, a claimant must show that his impairments prevent him from engaging in all forms of substantial gainful employment given his age, education, and work experience. See 42 U.S.C. §§ 423(d)(2), 1382c(a)(3)(B). In contrast, remand is appropriate if the ALJ’s analysis is so deficient that it “frustrate[s] meaningful review.” Mascio v. Colvin, 780 F.3d 632, 636 (4th Cir. 2015) (noting that “remand is necessary” where the court is “left to guess about how the ALJ arrived at his conclusions”). The ALJ must sufficiently articulate his findings such that the district court can undertake meaningful review. See Monroe v. Colvin, 826 F.3d 176,

189 (4th Cir. 2016). CLAIM HISTORY Joyce filed for Title II DIB and Title XVI SSI on March 25, 2022, alleging disability beginning June 11, 2021. R. 14. Her claim was denied initially on August 23, 2022, and again upon reconsideration on March 9, 2023. R. 62, 63, 82, 92. On March 21, 2023, Joyce requested a hearing, which was held by telephone on November 2, 2023. R. 31–57. Bruce Martin testified as an impartial vocational expert. R. 33. On December 18, 2023, the ALJ issued an “Unfavorable Decision” analyzing Joyce’s claim under the familiar five- step process4 finding that Joyce was not under a disability from June 11, 2021, through December 18, 2023, and denying her claim for benefits. R. 14–26.

4 The five-step process to evaluate a disability claim requires the Commissioner to ask, in sequence, whether the claimant: (1) is working; (2) has a severe impairment; (3) has an impairment that meets or equals the requirements of a listed impairment; (4) can return to his past relevant work; and if not, (5) whether he can perform other work. Johnson v. Barnhart, 434 F.3d 650, 654 n.1 (4th Cir. 2005) (per curiam) (citing 20 C.F.R.§ 404.1520); Heckler v. Campbell, 461 U.S. 458, 460-62, 103 S. Ct. 1952, 76 L. Ed. 2d 66 (1983). The inquiry ceases if the Commissioner finds the claimant disabled at any step of the process. 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4). The claimant bears the burden of proof at steps one through four to establish a prima facie case for disability.

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Durant v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/durant-v-commissioner-of-social-security-administration-vawd-2025.