Emmanuel Colas v. Commissioner of the Social Security Administration

CourtDistrict Court, E.D. New York
DecidedMarch 30, 2026
Docket2:23-cv-07838
StatusUnknown

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

Bluebook
Emmanuel Colas v. Commissioner of the Social Security Administration, (E.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF NEW YORK -------------------------------------------------------x EMMANUEL COLAS,

Plaintiff, MEMORANDUM & ORDER - against - 23-CV-7838 (PKC)

COMMISSIONER OF THE SOCIAL SECURITY ADMINISTRATION,

Defendant. -------------------------------------------------------x PAMELA K. CHEN, United States District Judge: Plaintiff Emmanuel Colas brings this action under 42 U.S.C. § 405(g), seeking judicial review of the Social Security Administration’s (“SSA”) denial of his claim for Disability Insurance Benefits (“DIB”). (Compl., Dkt. 1.) Plaintiff moves for judgment on the pleadings, asking this Court to remand to the SSA for a redetermination. (Pl.’s Mot. J. Pleadings, Dkt. 9.) The Commissioner of the SSA (“Commissioner” or “Defendant”) has filed a cross-motion for judgment on the pleadings (the “cross-motion”), asking this Court to affirm its determination. (Def.’s Cross-Mot. J. Pleadings, Dkt. 10.) For the reasons stated below, the Court grants Plaintiff’s motion for judgment on the pleadings and denies the Commissioner’s cross-motion. BACKGROUND I. Procedural History On September 4, 2020, Plaintiff filed for DIB with the SSA, alleging disability beginning on March 18, 2015. (Admin. Tr.1, Dkt. 6, at 93.) Plaintiff claimed that he was disabled due to

1 Page references prefaced by “Admin. Tr.” refer to the continuous pagination of the Administrative Transcript, (see Dkt. 6), appearing in the lower right corner of each page, and not to the internal pagination of the constituent documents or the pagination generated by the Court’s CM/ECF docketing system. fibromyalgia, neuropathy, migraine headaches, back pain, anxiety, and gastroesophageal reflux disorder. (Id.) Plaintiff asserted that, as a result of these conditions, he could not stand long enough to shave, took hours to cook, and could only walk for ten minutes before needing to rest for several hours. (Id. at 290–96.) Plaintiff’s claim for DIB was initially denied on February 3, 2021, (id. at

121), and again upon reconsideration on June 30, 2021, (id. at 128). On August 4, 2021, Plaintiff requested a hearing before an Administrative Law Judge (“ALJ”). (Id. at 140.) On January 13, 2022, a virtual hearing was held before ALJ Patrick Kilgannon. (Id. at 67–90.) At the hearing, Plaintiff amended the alleged onset date of his disability from March 18, 2015, to April 28, 2018, which was the date that Plaintiff was involved in a motor vehicle accident. (Id. at 70–71.) On June 28, 2022, the ALJ found that Plaintiff was not disabled within the meaning of the Social Security Act (the “Act”). (Id. at 12, 23.) On August 12, 2022, Plaintiff requested a review of that decision by the SSA Appeals Council.2 (Id. at 235–36.) On August 21, 2023, the Appeals Council denied review, and the ALJ’s decision became final. (Id. at 1.) On October 20, 2023, Plaintiff sought timely judicial review of the decision by this Court.3 (Compl., Dkt. 1.)

2 The Appeals Council “oversee[s] the [SSA’s] hearings and appeals process,” “promote[s] national consistency in hearing decisions” made by ALJs, and ensures that the Commissioner’s “records [are] adequate for judicial review.” Brief History and Current Information About the Appeals Council, Soc. Sec. Admin., https://www.ssa.gov/appeals/about_ac.html [https://perma.cc/QR7E-CZGP] (last visited Mar. 19, 2026). Upon “disagree[ment]” with the ALJ’s decision, a plaintiff may file an appeal with the Appeals Council. (Admin. Tr., Dkt. 6, at 8.) A plaintiff may send a written statement and any new evidence with the appeal. (Id. at 9.) The Appeals Council reviews all ALJ decisions and may deny the appeal, remand the case, issue its own decision, or dismiss the case. (Id. at 10.) 3 An individual may seek judicial review of any final decision of the Commissioner of within 60 days after the notice of decision is mailed to the claimant. 42 U.S.C. § 405(g). “Under the applicable regulations, the mailing of the final decision is presumed received five days after it is dated unless the claimant makes a reasonable showing to the contrary.” Kesoglides v. Comm’r of Soc. Sec., No. 13-CV-4724 (PKC), 2015 WL 1439862, at *3 (E.D.N.Y. Mar. 27, 2015) (first citing 20 C.F.R. §§ 404.981, 422.210(c); and then citing Matsibekker v. Heckler, 738 F.2d 79, 81 (2d Cir. 1984)). Accordingly, Plaintiff is presumed to have received the notice of decision on August 26, 2023. (Admin. Tr., Dkt. 6, at 1 (showing final decision date of August 21, 2023).) II. The ALJ’s Decision A. The Five-Step Inquiry 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 of not less than 12 months.” 42 U.S.C. § 423(d)(1)(A). The “relevant time period” under consideration is

the date of a plaintiff’s alleged onset of a disability to the date of last insured (“DLI”).4 See Kugielska v. Astrue, No. 06-CV-10169 (PKC), 2007 WL 3052204, at *2 (S.D.N.Y. Oct. 16, 2007). To determine whether an individual is entitled to disability benefits in the relevant time period, an ALJ applies a five-step inquiry, Lesterhuis v. Colvin, 805 F.3d 83, 86 n.2 (2d Cir. 2015), whereby the plaintiff bears the burden of proof at the first four steps of the inquiry, and the Commissioner bears the burden at the final step, Talavera v. Astrue, 697 F.3d 145, 151 (2d Cir. 2012). First, the ALJ must determine whether the plaintiff is currently engaged in “substantial gainful activity.” 20 C.F.R. § 404.1520(a)(4)(i). “Substantial gainful activity” is work activity done for pay or profit that involves significant physical or mental activities. Id. § 416.972. If the

answer is yes, the plaintiff is not disabled. Id. § 404.1520(a)(4)(i). If the answer is no, the ALJ

Since Plaintiff filed his Complaint on October 20, 2023, (Compl., Dkt. 1), less than 60 days later, this action is timely. 4 To be eligible for disability insurance benefits, an applicant must be “insured for disability . . . benefits.” See 42 U.S.C. § 423(a)(1)(A). Being insured requires that an individual accumulate the requisite number of “quarters of coverage.” Id. § 423(c)(1)(B); see also 20 C.F.R. §§ 404.120–404.146. The “date last insured,” or “DLI,” is the last day of the last quarter of coverage in which disability insured status is met. Callahan v. Astrue, No. 09-CV-1441 (TJM) (DRH), 2011 WL 2517022, at *8 (N.D.N.Y. May 5, 2011), report and recommendation adopted, No. 09-CV-1441, 2011 WL 2516707 (N.D.N.Y. June 23, 2011). A “claimant must establish disability on or before that date in order to be entitled to a period of disability and disability insurance benefits.” (Admin. Tr., Dkt. 6, at 12.) must proceed to step two.

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Bluebook (online)
Emmanuel Colas v. Commissioner of the Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/emmanuel-colas-v-commissioner-of-the-social-security-administration-nyed-2026.