Gonzalez-Nunez v. Commissioner of Social Security

CourtDistrict Court, D. Puerto Rico
DecidedMarch 31, 2025
Docket3:24-cv-01016
StatusUnknown

This text of Gonzalez-Nunez v. Commissioner of Social Security (Gonzalez-Nunez v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, D. Puerto Rico primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gonzalez-Nunez v. Commissioner of Social Security, (prd 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

LIANABEL G.N.1, Plaintiff, Civil No. 24-1016 (GLS) v.

COMMISSIONER OF SOCIAL SECURITY, Defendant.

OPINION AND ORDER

Plaintiff seeks review of the Commissioner of the Social Security Administration’s (the “SSA”) denial of her application for Social Security Disability Insurance benefits (“SSDI”). Docket No. 1. Plaintiff sustains that the decision should be reversed because it was not supported by substantial evidence and was based on incorrect legal standards. Docket No. 9. The Commissioner opposed. Docket No. 14. Plaintiff replied. Docket No. 17. The parties consented to the entry of judgment by a United States Magistrate Judge under the provisions of 28 U.S.C. §636(c). Docket No. 4. After careful review of the administrative record and the parties’ briefs, the Commissioner’s decision denying disability benefits is AFFIRMED. I. Procedural Background Plaintiff worked as a school secretary for the Department of Education until January 2018. Tr. 73, 856.2 On September 24, 2018, Plaintiff filed an application for SSDI claiming that, as of January 24, 2018, the following conditions limited her ability to work: fibromyalgia, diabetes, rheumatoid arthritis, major depression, peripheral neuropathy, insomnia, thyroids, low back pain, upper back pain, and retinopathy. Tr. 278, 578. Plaintiff received treatment of several doctors as evidenced by her disability report. The application was denied initially and upon reconsideration.

1 Plaintiff’s last name is omitted for privacy reasons.

2 “Tr.” refers to the transcript of the record of proceedings. Tr. 43, 564-602. Plaintiff requested a hearing before an Administrative Law Judge (“ALJ”) and, on August 10, 2022, a hearing was held before ALJ Angel X. Viera Vargas. Tr. 69-92. Plaintiff testified and was represented by counsel. Id. Vocational Expert (“VE”) María de León testified at the hearing. Id. On October 5, 2022, the ALJ issued a decision finding that Plaintiff was not disabled, as defined in the Social Security Act, from January 24, 2018, through the date of the decision. Tr. 43-59. Plaintiff asked the Appeals Council to review but the request was denied on November 27, 2023, rendering the Commissioner’s decision the final decision for review by this Court. Tr. 1-6. On January 11, 2024, Plaintiff initiated this action and both parties filed memoranda in support of their respective positions. Docket Nos. 9, 14, 17. II. Legal Framework A. Disability Determination by the SSA: Five Step Process To receive benefits under the Social Security Act, the ultimate question is whether plaintiff is disabled within the meaning of 42 U.S.C. §423(d). Disability is defined as the 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. See id. The severity of the impairment must be such that the claimant “is not only unable to do his previous work but cannot, considering his age, education, and work experience, engage in any other kind of substantial work which exists in the national economy.” 42 U.S.C. §423(d)(2)(A). The burden of proving disability rests on plaintiff. 42 U.S.C. § 423(d)(5)(A); Bowen v. Yuckert, 482 U.S. 137, 146 (1987). The Commissioner engages in a five-step sequential evaluation to determine whether a claimant is disabled. 20 C.F.R. §404.1520; Bowen, 482 U.S. at 140-42. At step one, the ALJ determines whether the claimant is engaged in “substantial gainful activity” and, if so, the claimant is not disabled. 20 C.F.R. §404.1520(b). If not engaged in substantial gainful activity, the Commissioner must determine whether the claimant has a medically severe impairment or combination of impairments that significantly limit his physical or mental ability to do basic work activities. 20 C.F.R. §404.1520(c). The step two severity requirement imposes a de minimis burden, which is designed to screen out groundless claims. McDonald v. Secretary, 795 F.2d 1118, 1123 (1st Cir. 1986). If the impairment or combination of impairments is severe, the third step applies. The ALJ must determine whether the claimant’s severe impairments meet the requirements of a “listed impairment”, which the Commissioner acknowledges are so severe as to preclude substantial gainful activity. See 20 C.F.R. §404.1520(d); 20 C.F.R. Part 404, Subpart P, App. 1. If the claimant has a “listed impairment” or an impairment equivalent in severity to a “listed impairment”, the claimant is considered disabled. If the claimant’s impairment does not meet the severity of a “listed impairment”, the ALJ must determine the claimant’s Residual Function Capacity (“RFC”). 20 C.F.R. §404.1520(e). An individual’s RFC is his ability to do physical and mental work activities on a sustained basis despite limitations due to impairments. 20 C.F.R. §404.1520(e); §404.1545(a)(1). At step four, the ALJ must determine, taking into consideration the RFC, whether the claimant can perform past relevant work. 20 C.F.R. §404.1520(f); §416.920(f). If not, then the fifth and final step applies. At steps one through four, the claimant has the burden of proving she cannot return to his former employment due to the alleged disability. Santiago v. Secretary, 944 F.2d 1, 5 (1st Cir. 1991). However, at step five, the Commissioner has the burden to prove the existence of other jobs in the national economy that claimant can perform. 20 C.F.R. §404.1520(g); Ortiz v. Secretary of Health & Human Services, 890 F.2d 520, 524 (1st Cir. 1989). If there are none, the claimant is entitled to disability benefits. 20 C.F.R. §404.1520(f). B. Standard of Review The Court may affirm, modify, reverse, or remand the decision of the Commissioner based on the pleadings and transcript. 42 U.S.C. §405(g).

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

Related

Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Mills v. Social Security
244 F.3d 1 (First Circuit, 2001)
Seavey v. Social Security
276 F.3d 1 (First Circuit, 2001)
United States v. Ilario M.A. Zannino
895 F.2d 1 (First Circuit, 1990)
Franklin Young v. Commissioner Social Security
519 F. App'x 769 (Third Circuit, 2013)
Purdy v. Berryhill
887 F.3d 7 (First Circuit, 2018)
Coskery v. Berryhill
892 F.3d 1 (First Circuit, 2018)

Cite This Page — Counsel Stack

Bluebook (online)
Gonzalez-Nunez v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gonzalez-nunez-v-commissioner-of-social-security-prd-2025.