Fogarty v. King

CourtDistrict Court, D. Minnesota
DecidedJanuary 7, 2025
Docket0:23-cv-03787
StatusUnknown

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

Bluebook
Fogarty v. King, (mnd 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

Gregory F.,1

Plaintiff, Case No. 23-cv-3787 (LMP/LIB)

v. REPORT AND RECOMMENDATION

Martin J. O’Malley, Commissioner of Social Security Administration,

Defendant.

Plaintiff, Gregory F. (hereinafter “Plaintiff”), seeks judicial review of the decision of the Commissioner of Social Security (“Defendant”) denying his application for disability benefits. The matter is before the undersigned United States Magistrate Judge for disposition pursuant to 28 U.S.C. § 636 and Local Rules 7.2(a)(1). This Court has jurisdiction over the claims under 42 U.S.C. § 405(g). Pursuant to the Federal Supplemental Rules of Civil Procedure which govern actions seeking judicial review of a decision of the Commissioner of Social Security, the present action “is presented for decision by the parties’ briefs.” Fed. R. Civ. P. Supp. SS Rule 5. Plaintiff filed a brief requesting reversal of the Commissioner’s final decision and remand to the Social Security Administration for an immediate award of benefits, or in the alternative, that the present action be remanded to the Social Security Administration for further consideration. [Docket No. 9]. Defendant filed a brief asking this Court to affirm the underlying decision denying Plaintiff’s request for benefits and to dismiss this action. [Docket No. 10].

1 This District has adopted the policy of using only the first name and last initial of any nongovernmental parties in Social Security opinions such as the present Report and Recommendation. Thus, when the Court refers to Plaintiff by his name only his first name and last initial are provided. For the reasons discussed herein, the undersigned recommends that Plaintiff’s request for relief, [Docket No. 9], be GRANTED in part and DENIED in part, and Defendant’s request for relief, [Docket No. 10], be DENIED. I. Background

On November 5, 2021, Plaintiff filed an application for disability benefits. (Tr. 15, 194– 195).2 Plaintiff alleged that his disability began on September 19, 2019. (Tr. 194). The Commissioner initially denied Plaintiff’s claim on December 17, 2021, and again, upon reconsideration, on May 19, 2022. (Tr. 15, 55–73). On June 17, 2022, Plaintiff filed a written request for a hearing before an Administrative Law Judge. (Tr. 15, 187–189). Administrative Law Judge Manh Nguyen (hereinafter “ALJ”) conducted a video hearing on April 4, 2023, at which Plaintiff was represented by legal counsel. (Tr. 15, 34–54). Plaintiff along with an independent vocational expert, Kelly Stroker (“IVE Stroker”), testified at the hearing. (Tr. 15, 34–54). On June 2, 2023, the ALJ issued a decision denying Plaintiff’s request for disability benefits.

(Tr. 12–27). The ALJ concluded that Plaintiff was not disabled within the meaning of the Social Security Act. (Tr. 27). Plaintiff thereafter sought review of the decision by the Appeals Council. (Tr. 1–11). Subsequently, on October 17, 2023, the Appeals Council denied Plaintiff’s request for review. (Tr. 1). As a result, the ALJ’s decision became the final decision of the Commissioner. See 20 C.F.R. §§ 404.981, 416.1481.

2 Throughout this Report and Recommendation, the Court refers to the Administrative Record, [Docket No. 7], by the abbreviation “Tr.” Where the Court cites to the Administrative Record, it refers to the page numbers found in the bottom-right corner of each page of the record. On December 12, 2023, Plaintiff filed this action. (Compl. [Docket No. 1]). Thereafter, this matter was presented to the Court for review pursuant to the parties’ briefs, [Docket Nos. 9, 10], and the Court took the matter under advisement on the written submissions. II. Standards of Review

A. Administrative Law Judge’s Five-Step Analysis If a claimant’s initial application for disability benefits is denied, he may request reconsideration of the decision. 20 C.F.R. §§ 404.907–404.909. A claimant who is dissatisfied with the reconsidered decision may then obtain administrative review by an administrative law judge. 42 U.S.C. § 405(b)(1); 20 C.F.R. § 404.929. To determine the existence and extent of a claimant’s disability, the administrative law judge must follow a five-step sequential analysis. This analysis requires the administrative law judge to make a series of factual findings about the claimant’s impairments, residual functional capacity, age, education, and work experience. See 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4); Locher v. Sullivan, 968 F.2d 725, 727 (8th Cir. 1992). The Eighth Circuit has described this five-

step process as follows: The Commissioner of Social Security [through the administrative law judge] must evaluate: (1) whether the claimant is presently engaged in a substantial gainful activity; (2) whether the claimant has a severe impairment that significantly limits the claimant’s physical or mental ability to perform basic work activities; (3) whether the claimant has an impairment that meets or equals a presumptively disabling impairment listed in the regulations; (4) whether the claimant has the residual functional capacity to perform his or her past relevant work; and (5) if the claimant cannot perform the past work, the burden shifts to the Commissioner to prove that there are other jobs in the national economy that the claimant can perform.

Dixon v. Barnhart, 353 F.3d 602, 605 (8th Cir. 2003). The claimant bears the burden under the Social Security Act of proving that he is disabled. See 20 C.F.R. § 404.1512(a); Whitman v. Colvin, 762 F.3d 701, 705 (8th Cir. 2014). Once the claimant has demonstrated he cannot perform any of his prior, relevant work due to a disability, the burden then shifts to the Commissioner to show that the claimant retains the residual functional capacity (“RFC”) to engage in some other substantial, gainful activity. Goff v. Barnhart, 421 F.3d 785, 790 (8th Cir. 2005).

B. Appeals Council Review If the claimant is dissatisfied with the administrative law judge’s decision, the claimant may request review by the Appeals Council, although the Appeals Council is not required to grant that request for review. See 20 C.F.R. §§ 404.967–404.982. The decision of the Appeals Council (or, if the request for review is denied by the Appeals Council, then the decision of the ALJ) is final and binding upon the claimant, unless the matter is appealed to federal court within sixty days after notice of the Appeals Council’s action. See 42 U.S.C. § 405(g); 20 C.F.R.

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