GLACKIN v. DUDEK

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 27, 2025
Docket2:23-cv-02038
StatusUnknown

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

Bluebook
GLACKIN v. DUDEK, (E.D. Pa. 2025).

Opinion

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

JEANNE MARIE G. : CIVIL ACTION Plaintiff, : : v. : No. 23-cv-2038 : LELAND DUDEK, : Acting Commissioner of Social Security, : Defendant. : MEMORANDUM OPINION CRAIG M. STRAW March 27, 2025 United States Magistrate Judge

Plaintiff Jeanne Marie G. (“Plaintiff”) seeks review of the Commissioner’s decision denying her application for Disability Insurance Benefits (“DIB”). The parties consented to proceed before a Magistrate Judge,1 and the matter was assigned to me.2 For the following reasons, I deny Plaintiff’s request for review and affirm the Commissioner’s decision. I. PROCEDURAL HISTORY

On August 4, 2020, Plaintiff filed an application for DIB under Title II of the Social Security Act (“SSA”), alleging a disability onset date (“AOD”) of October 24, 2018. R. 11, 40, 197. The claims were initially denied on January 20, 2021, and again on reconsideration. R. 11, 38, 97-98, 117-18. Plaintiff then requested review by an Administrative Law Judge (“ALJ”). R. 142-43. On December 7, 2021, ALJ Stuart Gauffreau held a hearing with Plaintiff, Plaintiff’s counsel Jess Levanthal, and Vocational Expert (“VE”) Daniel Rappucci.3 R. 11, 36.

1 See Doc. 5; 28 U.S.C. § 636(c) & Fed. R. Civ. P. 73. 2 See Doc. 3. 3 The hearing took place on the phone due to COVID-19 pandemic restrictions. R. 38 On January 10, 2022, the ALJ denied Plaintiff’s application for DIB. R. 12-24. Plaintiff requested review of the decision from the Appeals Council on January 19, 2022, which was denied. R. 1-3, 35. Plaintiff’s counsel then filed this action in federal court. Doc. 1. The parties subsequently submitted briefs addressing the relevant issues. Docs. 9-11.

II. LEGAL STANDARDS To prove a disability, the claimant must demonstrate an “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment . . . 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). The Commissioner employs a five-step sequential process to determine if a claimant is disabled, evaluating: 1. Whether the claimant is currently engaged in substantial gainful activity;

2. If not, whether the claimant has a “severe impairment” that significantly limits their physical or mental ability to perform basic work activities;

3. If so, whether based on the medical evidence, the impairment meets or equals the criteria of an impairment listed in the listing of impairments (“Listings,” see 20 C.F.R. pt. 404, subpt. P, app. 1), which results in a presumption of disability;

4. If the impairment does not meet or equal the criteria for a listed impairment, whether, despite the severe impairment, the claimant has the residual functional capacity (“RFC”) to perform their past work; and

5. If the claimant cannot perform their past work, whether there is other work in the national economy that the claimant can perform.

See Zirnsak v. Colvin, 777 F.3d 607, 611 (3d Cir. 2014); 20 C.F.R. § 404.1520(a)(4). Plaintiff bears the burden of proof at steps one through four, while the burden shifts to the Commissioner at step five to establish that the claimant can perform other jobs in the local and national economies based on their age, education, work experience, and RFC. See Poulos v. Comm’r of Soc. Sec., 474 F.3d 88, 92 (3d Cir. 2007). The court’s role on judicial review is to determine whether the Commissioner’s decision is supported by substantial evidence. See 42 U.S.C. § 405(g); Schaudeck v. Comm’r of Soc.

Sec., 191 F.3d 429, 431 (3d Cir. 1999). “Substantial evidence is ‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion,’” and must be “more than a mere scintilla but may be somewhat less than a preponderance of the evidence.” Zirnsak v. Colvin, 777 F.3d 607, 610 (3d Cir. 2014) (quoting Rutherford v. Barnhart, 399 F.3d 546, 552 (3d Cir. 2005); see also Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (explaining substantial evidence “means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion’”) (quoting Consol. Edison Co. v. NLRB, 305 U.S. 197, 229 (1938) (citation omitted). It is a deferential standard of review. Jones v. Barnhart, 364 F.3d 501, 503 (3d Cir. 2004) (citing Schaudek, 181 F.3d at 431)). III. ALJ’S DECISION AND PLAINTIFF’S REQUEST FOR REVIEW

The ALJ found that Plaintiff met the insured status requirement of the SSA through December 31, 2021. R. 13. Plaintiff had not engaged in substantial gainful activity since the AOD. R. 13. Plaintiff worked after the AOD, but this work activity did not result in sufficient earnings necessary to rise to the level of substantial gainful activity. R. 13, 202, 221-23; see also 20 C.F.R. § 404.1571, et seq. The ALJ found the following severe impairments: cervical spine disorder with radiculopathy, lumbar spine disorder with radiculopathy, Chiari malformation status-post decompression surgery with secondary headache disorder and cognitive dysfunction, depression, and anxiety.4 R. 13; see also 20 C.F.R. § 404.1520(c). The ALJ did not find any impairment, or a combination of impairments, that meet or medically equaled the severity of any Listings.5 R. 14; 20 C.F.R. pt. 404, subpt. P, app. 1; see also 20 C.F.R. §§ 404.1520(d), 404.1525, 404.1526. The ALJ also found that Plaintiff failed to meet the “paragraph B” criteria

because Plaintiff’s mental impairments did not cause at least two “marked” limitations or one “extreme limitation.”6 R. 16. Specifically, Plaintiff had moderate limitations in understanding, remembering, applying information, interacting with others, concentrating, persisting, maintaining pace, and adapting or managing oneself. R. 15. The ALJ further found that Plaintiff failed to meet the “paragraph C” criteria because the record did not show that Plaintiff has only marginal adjustment, that is, a minimal capacity to adapt to changes in Plaintiff’s environment or to demands that are not already part of Plaintiff’s daily life. R. 16. After considering the entire record, the ALJ found that Plaintiff had the RFC to perform sedentary work as defined in 20 C.F.R. § 404

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Arthur Poulos v. Commissioner of Social Security
474 F.3d 88 (Third Circuit, 2007)
Hodes v. Apfel
61 F. Supp. 2d 798 (N.D. Illinois, 1999)
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777 F.3d 607 (Third Circuit, 2014)
Cadillac v. Comm Social Security
84 F. App'x 163 (Third Circuit, 2003)
Salles v. Commissioner of Social Security
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Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Bennett v. Morris
5 Rawle 9 (Supreme Court of Pennsylvania, 1835)
Gamret v. Colvin
994 F. Supp. 2d 695 (W.D. Pennsylvania, 2014)

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GLACKIN v. DUDEK, Counsel Stack Legal Research, https://law.counselstack.com/opinion/glackin-v-dudek-paed-2025.