Fritz v. Commissioner of Social Security

CourtDistrict Court, M.D. Pennsylvania
DecidedAugust 13, 2021
Docket3:20-cv-00847
StatusUnknown

This text of Fritz v. Commissioner of Social Security (Fritz v. Commissioner of Social Security) 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
Fritz v. Commissioner of Social Security, (M.D. Pa. 2021).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA HEATHER L. FRITZ,

Plaintiff, CIVIL ACTION NO. 3:20-CV-00847

v. (MEHALCHICK, M.J.) COMMISSIONER OF SOCIAL SECURITY,

Defendant.

MEMORANDUM Plaintiff Heather L. Fritz brings this action under section 1631(c) of the Social Security Act, 42 U.S.C. § 1383(c) for judicial review of the final decision of the Commissioner of Social Security (the “Commissioner”) denying her application for supplemental security income under Title XVI of the Social Security Act. For the following reasons, the undersigned shall order the Commissioner’s decision be AFFIRMED. I. BACKGROUND AND PROCEDURAL HISTORY On March 30, 2018, Fritz filed an application under Title XVI for supplemental security income benefits, claiming disability beginning April 27, 2017. (Doc. 15-2, at 17). The Social Security Administration initially denied the application on June 20, 2018, prompting Fritz’s request for a hearing, which Administrative Law Judge (ALJ) Richard Zack held on May 3, 2019. (Doc. 15-2, at 17). In a June 26, 2019 written decision, the ALJ determined that Fritz is not disabled and therefore not entitled to benefits or income under Title XVI. (Doc. 15-2, at 17-27). The Appeals Council subsequently denied Fritz’s request for review. (Doc. 15-2, at 2). On May 26, 2020, Fritz commenced the instant action. (Doc. 1). The Commissioner responded on November 9, 2020, providing the requisite transcripts from Tavarez’s disability proceedings. (Doc. 14; Doc. 15). The parties then filed their respective briefs, with Fritz raising two principal bases for reversal or remand. (Doc. 16; Doc. 19; Doc. 21). II. STANDARDS OF REVIEW To receive benefits under XVI of the Social Security Act, 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. § 1382c(a)(3)(A); 20 C.F.R. § 416.909. To satisfy this requirement, a claimant must have a severe physical or mental impairment that makes it impossible to do his or her previous work or any other substantial gainful activity that exists in significant numbers in the national economy. 42 U.S.C. § 1382c(a)(3)(B); 20 C.F.R. § 416.905(a).1 A. ADMINISTRATIVE REVIEW The “Social Security Administration, working through ALJs, decides whether a claimant is disabled by following a now familiar five-step analysis.” Hess v. Comm’r Soc. Sec.,

931 F.3d 198, 200–01 (3d Cir. 2019). The “burden of proof is on the claimant at all steps except step five, where the burden is on the Commissioner of Social Security.” Hess, 931 F.3d at 201; see 20 C.F.R. § 416.912(a)(1). Thus, if the claimant establishes an inability to do past relevant work at step four, the burden shifts to the Commissioner at step five to show that jobs exist in significant numbers in the national economy that the claimant could perform

1 A “physical or mental impairment” is defined as an impairment resulting from “anatomical, physiological, or psychological abnormalities which are demonstrable by medically acceptable clinical and laboratory diagnostic techniques.” 42 U.S.C. § 1382c(a)(3)(D). consistent with his or her residual functional capacity, age, education, and past work experience. 20 C.F.R. § 416.912(a)(1). B. JUDICIAL REVIEW The Court’s review of a determination denying an application for Title XVI benefits is limited “to considering whether the factual findings are supported by substantial evidence.”

Katz v. Comm’r Soc. Sec., 798 F. App’x 734, 736 (3d Cir. 2019). Substantial evidence “does not mean a large or considerable amount of evidence, but rather such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Pierce v. Underwood, 487 U.S. 552, 565 (1988) (internal quotation marks omitted). The quantum of proof is less than a preponderance of the evidence but more than a mere scintilla. Richardson v. Perales, 402 U.S. 389, 401 (1971). A single piece of evidence is not substantial if the ALJ ignores countervailing evidence or fails to resolve a conflict created by such evidence. Mason v. Shalala, 994 F.2d 1058, 1064 (3d Cir. 1993). In an adequately developed factual record, substantial evidence may be “something less than the weight of the evidence, and the possibility of drawing two

inconsistent conclusions from the evidence does not prevent [the ALJ’s decision] from being supported by substantial evidence.” Consolo v. Fed. Maritime Comm’n, 383 U.S. 607, 620 (1966). The question before the Court, therefore, is not whether Fritz is disabled, but whether the Commissioner’s determination that Fritz is not disabled is supported by substantial evidence and was reached based upon a correct application of the relevant law. See Arnold v. Colvin, No. 3:12-CV-02417, 2014 WL 940205, at *1 (M.D. Pa. Mar. 11, 2014) (“[I]t has been held that an ALJ’s errors of law denote a lack of substantial evidence.”); Burton v. Schweiker, 512 F. Supp. 913, 914 (W.D. Pa. 1981) (“The [Commissioner]’s determination as to the status of a claim requires the correct application of the law to the facts.”); see also Wright v. Sullivan, 900 F.2d 675, 678 (3d Cir. 1990) (noting that the scope of review on legal matters is plenary). “In determining if the Commissioner’s decision is supported by substantial evidence the court must scrutinize the record as a whole.” Leslie v. Barnhart, 304 F. Supp. 2d 623, 627 (M.D. Pa.

2003). If “the ALJ’s findings of fact . . . are supported by substantial evidence in the record,” the Court is bound by those findings. Knepp v. Apfel, 204 F.3d 78, 83 (3d Cir. 2000). III. THE ALJ’S DECISION In his written decision, the ALJ determined that Fritz “has not been under a disability, as defined in the Social Security Act, since March 30, 2018, the date the application was filed.” (Doc. 15-2, at 27). The ALJ reached this conclusion after proceeding through the five- step sequential analysis provided in 20 C.F.R. § 416.920(a). A. STEP ONE At step one of the five-step analysis, the ALJ must determine whether the claimant is engaging in substantial gainful activity. 20 C.F.R.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Consolo v. Federal Maritime Commission
383 U.S. 607 (Supreme Court, 1966)
Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Warner-Lambert Company v. Breathasure, Inc.
204 F.3d 78 (Third Circuit, 2000)
Burton v. Schweiker
512 F. Supp. 913 (W.D. Pennsylvania, 1981)
Leslie v. Barnhart
304 F. Supp. 2d 623 (M.D. Pennsylvania, 2003)
Cop v. Commissioner of Social Security
226 F. App'x 203 (Third Circuit, 2007)
Russell Hess, III v. Commissioner Social Security
931 F.3d 198 (Third Circuit, 2019)

Cite This Page — Counsel Stack

Bluebook (online)
Fritz v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fritz-v-commissioner-of-social-security-pamd-2021.