GONZALEZ v. KIJAKAZI

CourtDistrict Court, E.D. Pennsylvania
DecidedFebruary 18, 2025
Docket5:23-cv-01511
StatusUnknown

This text of GONZALEZ v. KIJAKAZI (GONZALEZ v. KIJAKAZI) 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
GONZALEZ v. KIJAKAZI, (E.D. Pa. 2025).

Opinion

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

A.G.1 : CIVIL ACTION : v. : : MICHELLE KING, Acting : NO. 23-1511 Commissioner of Social Security2 :

MEMORANDUM AND ORDER

ELIZABETH T. HEY, U.S.M.J. February 18, 2025

Plaintiff seeks review of the Commissioner’s decision denying his application for supplemental security income (“SSI”). For the reasons that follow, I conclude that the decision of the Administrative Law Judge (“ALJ”) is supported by substantial evidence and affirm the Commissioner’s decision. I. PROCEDURAL HISTORY Plaintiff protectively filed an application for SSI on November 8, 2019, alleging disability beginning on May 1, 1996, as a result of a mood disorder, anxiety, alcohol, opioid, cannabis, cocaine and amphetamine-type use disorders, antisocial personality disorder, rosacea, seborrheic dermatitis, depressive disorder, and hepatitis C. Tr. at 87,

1Consistent with the practice of this court to protect the privacy interests of plaintiffs in social security cases, I will refer to Plaintiff using her initials. See Standing Order – In re: Party Identification in Social Security Cases (E.D. Pa. June 10, 2024). 2Michelle King was appointed as the Acting Commissioner of Social Security on January 20, 2025. Pursuant to Rule 25(d)(1) of the Federal Rules of Civil Procedure, Ms. King should be substituted as the defendant in this case. No further action need be taken to continue this suit pursuant to section 205(g) of the Social Security Act. 42 U.S.C. § 405(g). 244, 283.3 His application was denied initially, id. at 105-09, and on reconsideration, id. at 115-18, and he requested an administrative hearing. Id. at 123-24. After holding a hearing on October 18, 2021, id. at 42-71,4 the ALJ issued an unfavorable decision on

October 27, 2021. Id. at 17-29. The Appeals Council denied Plaintiff’s request for review on February 15, 2023, id. at 1-4, making the ALJ’s October 27, 2021 decision the final decision of the Commissioner. 20 C.F.R. § 416.1481. Plaintiff sought review in the federal court on April 20, 2023, Doc. 1,5 and the matter is now fully briefed and ripe for review. Docs. 12-13.6

II. LEGAL STANDARD The court’s role on judicial review is to determine whether the Commissioner’s decision is supported by substantial evidence. 42 U.S.C. § 405(g); Schaudeck v. Comm’r of Soc. Sec., 181 F.3d 429, 431 (3d Cir. 1999). Therefore, the issue in this case is

3Although Plaintiff alleged his onset date as May 1, 1996, for purposes of SSI his effective alleged onset date is his application date. See 20 C.F.R. § 416.305 (application required for eligibility to SSI benefits). Plaintiff filed three earlier applications for benefits in 2008, 2010, and 2011, but did not seek further review when they were denied at the initial consideration stage. Tr. at 73. 4The ALJ originally convened the hearing on April 6, 2021, but when Plaintiff reported he was at work in a factory, the ALJ rescheduled the hearing and suggested Plaintiff find an attorney. Tr. at 38-39. 5A claimant has 60 days after receipt of the Appeals Council’s notice to file an appeal in the court. 20 C.F.R. § 416.1481. The Administration allows 5 days after the date on the notice for receipt. See https://www.ssa.gov/ssi/text-appeals- ussi.htm#:~:text=If%20you%20want%20to%20appeal,are%20entitled%20to%20continu ed%20benefits. (last visited Jan. 13, 2025). Thus, Plaintiff’s appeal is timely filed. 6The parties have consented to magistrate judge jurisdiction pursuant to 28 U.S.C. § 636(c). See Standing Order – In Re: Direct Assignment of Social Security Appeals to Magistrate Judges – Extension of Pilot Program (E.D. Pa. Nov. 27, 2020); Doc. 6. whether there is substantial evidence to support the Commissioner’s conclusions that Plaintiff is not disabled. 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.” Zirnsak v. Colvin, 777 F.2d 607, 610 (3d Cir. 2014) (quoting Rutherford v. Barnhart, 399 F.3d 546, 552 (3d Cir. 2005)); see also Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (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)). The court has plenary review of legal issues.

Schaudeck, 181 F.3d at 431. To prove disability, a 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 . . . not less than twelve months.” 42 U.S.C. § 423(d)(1). The Commissioner employs a five-step process,

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 his physical or mental ability to perform basic work activities that has lasted or is expected to last for a continuous period of 12 months;

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”), 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 his past work; and

5. If the claimant cannot perform his past work, then the final step is to determine whether there is other work in the national economy that the claimant can perform.

See Zirnsak v. Colvin, 777 F.3d 607, 610 (3d Cir. 2014); see also 20 C.F.R. § 416.920(a)(4). Plaintiff bears the burden of proof at steps one through four, while the burden shifts to the Commissioner at the fifth step to establish that the claimant is capable of performing other jobs in the local and national economies, in light of his age, education, work experience, and RFC. See Poulos v. Comm’r of Soc. Sec., 474 F.3d 88, 92 (3d Cir. 2007). III. DISCUSSION A. ALJ’s Findings and Plaintiff’s Claims In her October 27, 2021 decision, the ALJ found at step one that Plaintiff has not engaged in substantial gainful activity since November 8, 2019, his application date. Tr.

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Janice Newell v. Commissioner of Social Security
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Arthur Poulos v. Commissioner of Social Security
474 F.3d 88 (Third Circuit, 2007)
Roseann Zirnsak v. Commissioner Social Security
777 F.3d 607 (Third Circuit, 2014)
Salles v. Commissioner of Social Security
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Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)

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GONZALEZ v. KIJAKAZI, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gonzalez-v-kijakazi-paed-2025.