Fidler v. O'Malley

CourtDistrict Court, M.D. Pennsylvania
DecidedMay 2, 2025
Docket4:24-cv-00586
StatusUnknown

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

Bluebook
Fidler v. O'Malley, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA MARK FIDLER, : Civil No. 4:24-cv-00586 : Plaintiff, : : v. : (Magistrate Judge Carlson) : LELAND DUDEK, : Acting Commissioner of Social Security1 : : Defendant. : MEMORANDUM OPINION I. Introduction To receive benefits under the Social Security Act by reason of disability, a claimant must demonstrate an 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); see also 20 C.F.R. §404.1505(a). To satisfy this requirement, a claimant must have a severe

1 Leland Dudek became the Acting Commissioner of Social Security on February 16, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Leland Dudek should be substituted for the previously named 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). 1 physical or mental impairment that makes it impossible to do his or her previous work or any other substantial gainful activity that exists in the national economy. 42

U.S.C. §423(d)(2)(A); 20 C.F.R. §404.1505(a). In making this determination at the administrative level, the ALJ follows a five-step sequential evaluation process to determine: (1) whether the claimant is engaged in substantial gainful activity; (2)

whether the claimant has a severe impairment; (3) whether the claimant’s impairment meets or equals a listed impairment; (4) whether the claimant is able to do his or her past relevant work; and (5) whether the claimant is able to do any other work, considering his or her age, education, work experience and residual functional

capacity (“RFC”). 20 C.F.R. §404.1520(a)(4). At Step 2 of this sequential analysis, an administrative law judge (ALJ) determines whether a claimant has a medically severe impairment or combination of

impairments which impact a claimant’s ability to perform work-related activity. “In order to meet the step two severity test, an impairment need only cause a slight abnormality that has no more than a minimal effect on the ability to do basic work activities.” 20 C.F.R. §§ 404.1521, 416.921; S.S.R. 96–3p, 85–28. Thus, the Third

Circuit Court of Appeals has described this Step 2 inquiry as a “de minimus screening device to dispose of groundless claims” McCrea v. Comm. of Soc. Sec., 370 F.3d 357, 360 (3d Cir. 2004), and “[a]ny doubt as to whether this showing has

2 been made is to be resolved in favor of the applicant,” Velazquez v. Astrue, No. 07– 5343, 2008 WL 4589831, *3 (E.D. Pa., Oct. 15, 2008).

Despite this de minimis standard, it is still axiomatic that the “[p]laintiff retains the burden of showing that an impairment is severe,” by “present[ing] evidence that a limitation significantly limited his ability to do basic work activities.”

Gunn v. Kijakazi, 705 F. Supp. 3d 315, 322-23 (E.D. Pa. 2023) (citing Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987); Salles v. Comm'r of Soc. Sec., 229 F. App'x 140, 145 (3d Cir. 2007); Ramirez v. Barnhart, 372 F.3d 546, 551 (3d Cir. 2004)). Moreover, “absent a ‘medically determinable physical or mental impairment,’ an

individual must be found not disabled at step two and ‘[n]o symptom or combination of symptoms can be the basis for a finding of disability . . . unless there are medical signs and laboratory findings demonstrating the existence of a medically

determinable physical or mental impairment.’” Perez v. Comm'r of Soc. Sec., 521 F. App'x 51, 55 (3d Cir. 2013) (quoting SSR 96–4p, 1996 WL 374187, at *1 (July 2, 1996)). So it is here.

The plaintiff in this case, Mark Fidler, applied for disability benefits in May 2022, alleging an onset of his disability on November 1, 2021, due to pain in his legs. But Fidler presented no evidence at the application, reconsideration, or hearing

3 stages of his disability proceeding that his conditions were disabling or that he sought treatment for his conditions prior to August 2022, long after the disability

period, which ended on December 31, 2021. Thus, having no evidence upon which to base any finding that Fidler suffered from a determinable impairment, the ALJ found at Step 2 that Fidler had not met the standard to prove he was disabled during

the relevant period. Fidler now appeals this decision, arguing that the ALJ erred in finding insufficient evidence to establish the presence of a determinable impairment at Step 2 and in failing to obtain a medical expert. However, in our view, given the paucity

of any “medical signs and laboratory findings demonstrating the existence of a medically determinable physical or mental impairment.’” Perez at 55, we find this is one of the rare cases where the de minimus requirement at Step 2 has simply not

been met. Therefore, after a review of the record, and mindful of the fact that substantial evidence “means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion,’” Biestek, 139 S. Ct. at 1154, we find that substantial evidence supported the ALJ’s findings in this case. For the

reasons set forth below, we will affirm the decision of the Commissioner denying this claim.

4 II. Statement of Facts and of the Case

The meager administrative record of the plaintiff’s disability application reveals the following essential facts: On May 24, 2022, Fidler filed a Title II application for a period of disability and disability insurance benefits alleging an onset of his disability on November 1, 2021. (Tr. 17). The record reveals that Fidler

stopped working in 2016 to take care of his mother, leaving his date last insured as December 31, 2021. (Tr. 30, 154). Thus, the relevant disability period encompasses only two months’ time, between the beginning of November and end of December 2021. His disability application alleged he was unable to work due to an inability to

read or write,2 pain in both legs, and left arm pain. (Tr. 158). He testified that he had to stop taking care of his mother on November 1, 2021, because his legs were swollen and painful and he was “falling all over the place.” (Tr. 36). Fidler was born

on December 22, 1966, and was fifty-four years old at the time of the alleged onset of his disability and fifty-five on his date last insured. (Tr. 154). He has a tenth-grade education and, prior to leaving the workforce in 2016 worked as a butcher and a bag thrower for a garbage disposal company. (Tr. 188).

2 Despite listing this as a reason for his disability, in his disability report he indicated he can read and understand English and write more than his name in English.

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Consolo v. Federal Maritime Commission
383 U.S. 607 (Supreme Court, 1966)
Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Dickinson v. Zurko
527 U.S. 150 (Supreme Court, 1999)
Janice Newell v. Commissioner of Social Security
347 F.3d 541 (Third Circuit, 2003)
Shirley McCrea v. Commissioner of Social Security
370 F.3d 357 (Third Circuit, 2004)
Maria Perez v. Commissioner Social Security
521 F. App'x 51 (Third Circuit, 2013)
Diaz v. Commissioner of Social Security
577 F.3d 500 (Third Circuit, 2009)

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Bluebook (online)
Fidler v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fidler-v-omalley-pamd-2025.