Fallanca v. O'Malley

CourtDistrict Court, S.D. New York
DecidedFebruary 25, 2025
Docket1:24-cv-01820
StatusUnknown

This text of Fallanca v. O'Malley (Fallanca v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Fallanca v. O'Malley, (S.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK

STEVEN MICHAEL F.,1

Plaintiff,

-v- CIVIL ACTION NO. 24 Civ. 1820 (RFT)

LEE DUDEK, ACTING COMMISSIONER OPINION & ORDER OF SOCIAL SECURITY,2

Defendant.

ROBYN F. TARNOFSKY, UNITED STATES MAGISTRATE JUDGE Before the Court is Defendant’s mo�on for judgment on the pleadings. (See ECF 22, Def.’s Br.) Also before the Court are Plain�ff Steven Michael F.’s pe��on for review and cross- mo�on for judgment on the pleadings seeking judicial review of a final determina�on by Defendant Lee Dudek, Ac�ng Commissioner of the Social Security Administra�on (the “SSA”), dismissing his request for Appeals Council review of the determina�on by the Administra�ve Law Judge (the “ALJ”) of liability under the Social Security Act (the “Act”) for repayment of overpayments, on the ground of failure to file a �mely request for review. (See ECF 27, Pl.’s Mot. at 1-2.) Having carefully reviewed the administra�ve record (the “Record”) and the submissions of the par�es, and for the reasons set forth below, the Commissioner’s mo�on for judgment on the pleadings is GRANTED; Plain�ff’s cross-mo�on is DENIED; and Plain�ff’s pe��on for review is DISMISSED.

1 To protect Plain�ff’s privacy, he is iden�fied by his first and middle names and last ini�al. 2 Lee Dudek is the Ac�ng Commissioner of the Social Security Administra�on. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, he is subs�tuted as the defendant in this ac�on. BACKGROUND I. Procedural History

In November 2017, Plain�ff was found disabled and en�tled to disability insurance benefits. (R. at 107-17; ECF 22, Def.’s Opp. at 1.)3 The SSA awarded Plain�ff’s children, Angelia F. and Michael F., child’s benefits on Plain�ff’s account; Giovanna F. was assigned as the children’s representa�ve payee (the “Children’s Representa�ve”). (R. at 118-29.) On August 24, 2020, Plain�ff and the Children’s Representa�ve were no�fied that the SSA had overpaid their

benefits. (Id. at 136-49.) On September 17, 2020, Plain�ff submited a request for reconsidera�on. (Id. at 23, 150.) Between January 11, 2021 and January 18, 2021, the SSA sent addi�onal no�ces of overpayment for new amounts to Plain�ff and the Children’s Representa�ve. (Id. at 151-73.) On March 20, 2021 and March 22, 2021, the SSA denied Plain�ff’s request for reconsidera�on and issued no�ces to Plain�ff and the Children’s Representa�ve advising them of their total overpaid amounts due. (Id. at 175-88.)

On April 27, 2021, Plain�ff submited a request for hearing before an ALJ. (Id. at 189-90.) That same day, the Children’s Representa�ve, on behalf of the children, filed addi�onal hearing requests. (Id. at 191-94.) The ALJ issued a decision as to all par�es on March 21, 2023, finding that the SSA cannot waive the overpayments and holding Plain�ff liable for the amounts due for himself and his children. (Id. at 27.)

3 Cita�ons to “R.” are to the administra�ve record, and the page cita�ons are to the black numbers in the top right corner of each page and not to the blue numbers at the top of the page that are part of the ECF numbering system. The ALJ’s March 21 no�ce of decision required Plain�ff to file a writen request for review to the Appeals Council within sixty days of receipt (id. at 20), and Plain�ff is assumed to have received the no�ce five days a�er its issue date. On June 30, 2023, thirty-six days a�er the

deadline set by the ALJ’s no�ce of decision, Plain�ff, through counsel, sent his request for review to the Appeals Council. (Id. at 18-19.) Plain�ff alleges good cause for failing to meet the deadline due to flare-ups of back pain that required over-the-counter medica�on, being somewhat depressed, and feeling embarrassment for needing to go outside the family for legal assistance. (Id.)

On January 3, 2024, the Appeals Council denied Plain�ff’s request for review, finding a lack of good cause for un�meliness under current regula�ons. (See id. at 4-5.) On March 8, 2024, sixty days a�er it is assumed that Plain�ff received the no�ce of dismissal, Plain�ff �mely filed this ac�on seeking judicial review of the Appeals Council’s dismissal, pursuant to 42 U.S.C. § 405(g). (See id. at 2; ECF 1, Compl.; ECF 2, Corrected Compl.) On September 6, 2024, Defendant filed a brief opposing Plain�ff’s request for judicial review; Defendant referred to a

mo�on for judgment on the pleadings but does not appear to have filed such a mo�on; nevertheless, I treat Defendant’s filing as a mo�on for judgment on the pleadings. (See generally ECF 22, Def.’s Br.) On December 19, 2024, Plain�ff responded by filing a mo�on for judgment on the pleadings, which included his arguments in support of gran�ng his mo�on; I construe this filing as a cross-mo�on for judgment on the pleadings. (See generally ECF 27, Pl.’s Mot.) On January 2, 2025, Defendant filed a brief in response to Plain�ff’s cross-mo�on and in

further support of its mo�on. (ECF 28, Def.’s Reply.) DISCUSSION I. Legal Standards

“A mo�on for judgment on the pleadings should be granted if it is clear from the pleadings that the moving party is en�tled to judgment as a mater of law.” Hayward v. Comm’r of Soc. Sec., No. 18-CV-10402 (SN), 2021 WL 982296, at *3 (S.D.N.Y. Mar. 16, 2021) (quo�ng Burns Int’l Sec. Servs., Inc. v. Int’l Union, United Plant Guard Workers of Am. (UPGWA) & Its Local 537, 47 F.3d 14, 16 (2d Cir. 1995)); see also Fed. R. Civ. P. 12(c).4

An individual may file a civil ac�on seeking judicial review of any final determina�on made by the Commissioner within sixty days a�er mailing of such no�ce of decision. See 42 U.S.C. § 405(g). “[W]here the SSA’s Appeals Council has dismissed a request for review as un�mely a�er a claimant has obtained a hearing from an ALJ on the merits, that dismissal qualifies as a final decision . . . within the meaning of § 405(g).” Smith v. Berryhill, 587 U.S. 471, 489 (2019). If the SSA dismissed a case on procedural grounds, the court should restrict its

review to the procedural basis for the Appeals Council’s dismissal. See Hayward, 2021 WL 982296, at *3. Procedural decisions are reviewed under an “abuse of discre�on” standard as to the conclusion and under a “substan�al evidence” standard as to factual determina�ons. See id.; see also 42 U.S.C. § 405(g). “[I]f substan�al evidence supports the Commissioner’s determina�on that a claimant did not �mely request review, a court will review the agency’s good cause determina�on for abuse of discre�on.” Hayward, 2021 WL 982296, at *3; see also

Bowen v. City of New York, 476 U.S. 467, 483 (1986). The reviewing court is limited to

4 Unless otherwise indicated, this Opinion and Order omits all internal quota�on marks, cita�ons, footnotes, omissions, emphases, and altera�ons in quoted text. determining whether the SSA’s conclusions were based on the correct legal standard and supported by “more than a mere scin�lla” of evidence. Brown v. Berryhill, No. 15-CV-8201 (VSB) (BCM), 2017 WL 2493275, at *5 (S.D.N.Y. Mar. 3, 2017).

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Fallanca v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fallanca-v-omalley-nysd-2025.