Garcia v. Dudek

CourtDistrict Court, M.D. Pennsylvania
DecidedMarch 3, 2025
Docket1:24-cv-00194
StatusUnknown

This text of Garcia v. Dudek (Garcia v. Dudek) 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.

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Garcia v. Dudek, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

GASPAR LUPIAN GARCIA, : CIVIL NO.: 1:24-cv-00194 : Plaintiff, : (Magistrate Judge Schwab) : v. : : : LELAND DUDEK, 1 : Acting Commissioner of : Social Security, : : Defendant. :

MEMORANDUM OPINION I. Introduction. In this social security action, Plaintiff Gaspar Lupian Garcia seeks judicial review of the final decision of the Commissioner of Social Security (“Commissioner”) denying his claims for disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. We have jurisdiction under 42 U.S.C. §§ 405(g) and 1383(c)(3). For the reasons

1 Leland Dudek is now the Acting Commissioner of Social Security, and he is automatically substituted as the defendant in this action. See Fed. R. Civ. P. 25(d) (providing that when a public officer sued in his or her official capacity ceases to hold office while the action is pending, “[t]he officer’s successor is automatically substituted as a party”); 42 U.S.C. § 405(g) (“Any action instituted in accordance with this subsection shall survive notwithstanding any change in the person occupying the office of Commissioner of Social Security or any vacancy in such office.”). set forth below, we will vacate the Commissioner’s decision and remand the case to the Commissioner for further proceedings.

II. Background and Procedural History. We refer to the transcript provided by the Commissioner. See docs. 9 -1 to 9- 9.2 On June 19, 2019, Garcia protectively filed3 an application for disability insurance benefits and an application for supplemental security income, alleging

that he has been disabled since May 14, 2019. See Admin. Tr. at 351–59. After the Commissioner denied his claims at the initial and reconsideration levels of administrative review, id. at 72–89, 92–114, Garcia requested an administrative hearing, id. at 147–48. In January 2023, Garcia—who was represented by

counsel—as well as a vocational expert testified at a hearing before Administrative Law Judge Richard Guida (the “ALJ”). Id. at 38–65. In January 2023, the ALJ denied Garcia’s claims for benefits. Id. at 16–36. Garcia appealed the ALJ’s

decision to the Appeals Council, which denied his request for review. Id. at 1–8.

2 Because the facts of this case are well known to the parties, we do not repeat them here in detail. Instead, we recite only those facts that bear on Garcia’s claims. 3 “Protective filing is a term for the first time an individual contacts the Social Security Administration to file a claim for benefits.” Stitzel v. Berryhill, No. 3:16-CV-0391, 2017 WL 5559918, at *1 n.3 (M.D. Pa. Nov. 9, 2017). “A protective filing date allows an individual to have an earlier application date than the date the application is actually signed.” Id. This makes the ALJ’s decision the final decision of the Commissioner subject to judicial review by this Court.

In February 2024, Garcia, represented by counsel, began this action by filing a complaint seeking review of the Commissioner’s decision denying his claims. See Doc. 1. He requests that the court award him benefits or, in the alternative,

remand the case for further proceedings. Id. at 3 (Wherefore Clause). He also seeks “such relief” as the court deems justified, including attorney’s fees. Id. The parties consented to proceed before a magistrate judge pursuant to 28 U.S.C. § 636(c), and the case was referred to the undersigned. Doc. 7. The

Commissioner then filed an answer and a certified transcript of the administrative proceedings. Docs. 8, 9. The parties filed briefs, see docs. 15, 17, 20, and this matter is ripe for decision.

III. Legal Standards. A. Substantial Evidence Review—the Role of This Court. When reviewing the Commissioner’s final decision denying a claimant’s

application for benefits, “the court has plenary review of all legal issues decided by the Commissioner.” Ficca v. Astrue, 901 F. Supp. 2d 533, 536 (M.D. Pa. 2012). But the court’s review of the Commissioner’s factual findings is limited to whether

substantial evidence supports those findings. See 42 U.S.C. § 405(g); Biestek v. Berryhill, 587 U.S. 97, 99 (2019). “[T]he threshold for such evidentiary sufficiency is not high.” Biestek, 587 U.S. at 103. Substantial evidence “means—

and means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Id. (quoting Consol. Edison Co. of New York v. N.L.R.B., 305 U.S. 197, 229 (1938)).

Substantial evidence “is less than a preponderance of the evidence but more than a mere scintilla.” Jesurum v. Sec’y of U.S. Dep’t of Health & Human Servs., 48 F.3d 114, 117 (3d Cir. 1995). A single piece of evidence is not substantial evidence if the ALJ ignores countervailing evidence or fails to resolve a conflict

created by the evidence. Mason v. Shalala, 994 F.2d 1058, 1064 (3d Cir. 1993). But 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] finding from being supported by substantial evidence.” Consolo v. Fed. Maritime Comm’n, 383 U.S. 607, 620 (1966). “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). The question before this court, therefore, is not whether Garcia is disabled, but whether substantial evidence supports the Commissioner’s finding that he is

not disabled and whether the Commissioner correctly applied the relevant law. B. Initial Burdens of Proof, Persuasion, and Articulation. To receive benefits under Title II or Title XVI of the Social Security Act, a claimant generally 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 42 U.S.C. §1382c(a)(3)(A); 20 C.F.R. §§ 404.1505(a), 416.905(a). 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 work that exists in the national economy. 42 U.S.C. §§ 423(d)(2)(A), 1382c(a)(3)(B); 20 C.F.R.

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Consolo v. Federal Maritime Commission
383 U.S. 607 (Supreme Court, 1966)
Kacee Chandler v. Commissioner Social Security
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Diaz v. Commissioner of Social Security
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Brownawell v. Commissioner of Social Security
554 F.3d 352 (Third Circuit, 2008)
Johnson v. Commissioner of Social Security
529 F.3d 198 (Third Circuit, 2008)
Leslie v. Barnhart
304 F. Supp. 2d 623 (M.D. Pennsylvania, 2003)
Titterington v. Comm Social Security
174 F. App'x 6 (Third Circuit, 2006)

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