Elizabeth Martínez Valentín v. Frank J. Bisignano, Commissioner of Social Security

CourtDistrict Court, D. Puerto Rico
DecidedMarch 16, 2026
Docket3:25-cv-01184
StatusUnknown

This text of Elizabeth Martínez Valentín v. Frank J. Bisignano, Commissioner of Social Security (Elizabeth Martínez Valentín v. Frank J. Bisignano, Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, D. Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Elizabeth Martínez Valentín v. Frank J. Bisignano, Commissioner of Social Security, (prd 2026).

Opinion

1 IN THE UNITED STATES DISTRICT COURT 2 FOR THE DISTRICT OF PUERTO RICO

5 ELIZABETH MARTÍNEZ VALENTÍN, 6 Plaintiff, 7 CIVIL NO. 25-1184 (HRV) v. 8

9 FRANK J. BISIGNANO Commissioner of Social Security, 10

11 Defendant.

13 OPINION AND ORDER1 14 Elizabeth Martínez-Valentín (hereinafter “Plaintiff” or “Ms. Martínez”) seeks 15 16 review of the final administrative decision of the Commissioner of Social Security (“the 17 Commissioner”) denying her claim for disability benefits under the Social Security Act 18 (“the Act”). The Commissioner filed his brief arguing that the decision should be affirmed 19 because it is based on substantial evidence. The parties have consented to the entry of 20 judgment by a United States Magistrate Judge under the provisions of 28 U.S.C. § 636(c). 21 22 After careful consideration of the record, and for the reasons outlined below, the 23 Commissioner’s decision is AFFIRMED. 24

26 1 Marielena Negrón-Rivera, a third-year law student at the University of Puerto Rico School of Law, 27 provided significant assistance in the research and drafting of this Opinion and Order.

28 1 1 I. LEGAL FRAMEWORK 2 A. Standard of Review 3 Pursuant to 42 U.S.C. § 405(g), any individual may obtain review of a final 4 decision of the Commissioner in which he or she was a party. Under said provision, the 5 Court is empowered “to enter, upon the pleadings and transcript of the record, a 6 7 judgment affirming, modifying, or reversing the decision of the Commissioner [. . .]” Id. 8 In addition, the statute provides that if supported by substantial evidence, the findings 9 of the Commissioner as to any fact, shall be conclusive. Id. 10 A reviewing Court must uphold the decision of the Commissioner if the 11 Administrative Law Judge (“ALJ”) applied the correct legal principles, and the 12 13 determination is supported by substantial evidence. Seavey v. Barnhart, 276 F.3d 1, 9 14 (1st Cir. 2001). The scope of my review is thus limited. I am tasked with determining 15 whether the ALJ employed the proper legal standards and focused facts upon the proper 16 quantum of evidence. See Ward v. Comm’r of Soc. Sec., 211 F.3d 652, 655 (1st Cir. 2000); 17 see also Manso-Pizarro v. Sec’y of Health and Human Servs., 76 F.3d 15, 16 (1st Cir. 18 19 1996). 20 To meet the evidentiary benchmark, more than a scintilla of evidence is required. 21 Purdy v. Berryhill, 887 F.3d 7, 13 (1st Cir. 2018). But the threshold for evidentiary 22 sufficiency is not particularly high; if after looking at the existing administrative record, 23 the reviewing court is persuaded that it contains sufficient evidence to support the 24 Commissioner’s factual determinations, the decision is bound to be upheld. See Biestek 25 26 v. Berryhill, 587 U.S. 97, 102-03 (2019) (cleaned up). Substantial evidence exists when 27 “a reasonable mind, reviewing the evidence in the record, could accept it as adequate to 28 2 1 support [the] conclusion.” Irlanda-Ortiz v. Sec’y of Health & Human Servs., 955 F.2d 2 765, 769 (1st Cir. 1991). The ALJ’s decision must be reversed, however, if it was arrived 3 at “by ignoring evidence, misapplying law, or judging matters entrusted to experts.” 4 Nguyen v. Chater, 172 F.3d 31, 35 (1st Cir. 1999). 5 B. The Five-Step Sequential Evaluation Process 6 7 To be eligible for social security benefits, a claimant must demonstrate that he or 8 she is “disabled” within the meaning of the Act. Bowen v. Yuckert, 482 U.S. 137, 146, 9 (1987). The Act defines disability as the inability “to engage in any substantial gainful 10 activity by reason of any medically determinable physical or mental impairment which 11 has lasted or can be expected to last for a continuous period of not less than twelve 12 13 months.” 42 U.S.C. §§ 423(d)(1)(a) and 1382c(a)(3)(A). “Substantial gainful activity” 14 means work that is considered both substantial and gainful. Peters v. Colvin, 133 F. Supp. 15 3d 273, 278-79 (D. Mass. 2015). Substantial work is defined as work that involves 16 significant physical or mental activity. Id. On the other hand, gainful work is “any work 17 done for profit, whether or not profit is realized”. Id. The impairment or impairments 18 19 must be severe enough that a claimant “is not only unable to do his [or her] previous 20 work but cannot . . . engage in any other kind of substantial gainful work which exists [in 21 significant numbers] in the national economy….” 42 U.S.C. § 423(d)(2), § 22 1382c(a)(3)(B); see also 20 C.F.R. § 404.1520(a)(1). 23 The Commissioner follows a five-step evaluation process to determine disability. 24 See Mills v. Apfel, 244 F.3d 1, 2 (1st Cir. 2001); 20 C.F.R. § 404.1520(a). These steps must 25 26 be followed in order, and if a person is determined not to be disabled at any step, the 27 inquiry stops. Id. The Plaintiff has the burden of proof at the first four steps of the process. 28 3 1 Freeman v. Barnhart, 274 F.3d 606, 608 (1st Cir. 2001); Bowen v. Yuckert 482 U.S. at 2 146. 3 Step one considers work activity, that is, whether the Plaintiff is currently “doing 4 substantial gainful activity.” 20 C.F.R. § 404.1520(a)(4)(i). If the person is, then she is 5 not disabled under the Act. Id. Step two asks whether Plaintiff has a physical or mental 6 7 impairment, or a combination of impairments, that is severe and meets the Act’s 8 duration requirement. 20 C.F.R. § 404.1520(a)(4)(ii). Step three considers the medical 9 severity of the Plaintiff’s impairments. 20 C.F.R. § 404.1520(a)(4)(iii). At this step, if 10 Plaintiff is determined to have an impairment that meets or equals an impairment listed 11 in 20 C.F.R. pt. 404, Subpt. P., app. 1, and meets the duration requirements, she is 12 13 disabled. 20 C.F.R. § 404.1520(a)(4)(iii). On the other hand, if the Plaintiff is not found 14 to be disabled at this step, her Residual Functional Capacity (“RFC”) is assessed. 20 C.F.R. 15

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Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Ward v. Commissioner of Social Security
211 F.3d 652 (First Circuit, 2000)
Mills v. Social Security
244 F.3d 1 (First Circuit, 2001)
Seavey v. Social Security
276 F.3d 1 (First Circuit, 2001)
Freeman v. Massanari
274 F.3d 606 (First Circuit, 2001)
American Eastern Corporation v. United States
133 F. Supp. 11 (S.D. New York, 1955)
Purdy v. Berryhill
887 F.3d 7 (First Circuit, 2018)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Small v. Astrue
840 F. Supp. 2d 458 (D. Massachusetts, 2012)
Juanita Cross v. Martin O'Malley
89 F.4th 1211 (Ninth Circuit, 2024)

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Elizabeth Martínez Valentín v. Frank J. Bisignano, Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/elizabeth-martinez-valentin-v-frank-j-bisignano-commissioner-of-social-prd-2026.