Hajdarevic v. O'Malley

CourtDistrict Court, M.D. Pennsylvania
DecidedApril 3, 2025
Docket3:24-cv-00636
StatusUnknown

This text of Hajdarevic v. O'Malley (Hajdarevic v. O'Malley) 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
Hajdarevic v. O'Malley, (M.D. Pa. 2025).

Opinion

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

MIRSAD HAJDAREVIC, : Civil No. 3:24-cv-00636 : Plaintiff, : : v. : (Magistrate Judge Carlson) : LELAND DUDEK, : Acting Commissioner of Social Security1 : : Defendant. :

MEMORANDUM OPINION

I. Introduction The Supreme Court has underscored for us the limited scope of our substantive review when considering Social Security appeals, noting that: The phrase “substantial evidence” is a “term of art” used throughout administrative law to describe how courts are to review agency factfinding. T-Mobile South, LLC v. Roswell, 574 U.S. ––––, ––––, 135 S. Ct. 808, 815, 190 L.Ed.2d 679 (2015). Under the substantial- evidence standard, a court looks to an existing administrative record and asks whether it contains “sufficien[t] evidence” to support the agency’s factual determinations. Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S. Ct. 206, 83 L.Ed. 126 (1938) (emphasis deleted). And whatever the meaning of “substantial” in other contexts,

1 Leland Dudek became the Acting Commissioner of Social Security on February 16, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Leland Dudek should be substituted for the previously named defendant in this suit. No further action need be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g).

1 the threshold for such evidentiary sufficiency is not high. Substantial evidence, this Court has said, is “more than a mere scintilla.” Ibid.; see, e.g., Perales, 402 U.S. at 401, 91 S. Ct. 1420 (internal quotation marks omitted). It means—and means only—“such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Consolidated Edison, 305 U.S. at 229, 59 S. Ct. 206. See Dickinson v. Zurko, 527 U.S. 150, 153, 119 S. Ct. 1816, 144 L.Ed.2d 143 (1999) (comparing the substantial-evidence standard to the deferential clearly- erroneous standard). Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019). The plaintiff in this case, Mirsad Hajdarevic, suffered a work-related injury in December 2019 which resulted in an array of impairments to his lumbar spine, right hand and elbow, and left knee. The longitudinal medical evidence was mixed and equivocal, showing relatively benign examination findings and conservative treatment but ongoing complaints of chronic pain, and the medical opinion evidence regarding the disabling effects of these impairments was split, with two examining sources, including consultative examiner Dr. Ahmed Kneifati, finding Hajdarevic would only be capable of sedentary or less work, and the two State agency experts and one examining physician, Dr. Baker, opining that he was capable of light work with some postural limitations. Following a hearing before an Administrative Law

Judge (“ALJ”), the ALJ found that Hajdarevic could perform a range of light work with a modified sit/stand option and certain postural limitations. Based on this residual functional capacity assessment (RFC), the ALJ concluded other work

2 existed in the national economy that Hajdarevic could perform and so he had not met the exacting standard of disability set by law.

Hajdarevic now appeals this decision, arguing that the ALJ failed to properly evaluate the opinion of consultative examiner Dr. Kneifati and that the ALJ committed various errors in evaluating the disabling effects of his impairments.

However, after a review of the record, and mindful of the fact that substantial evidence “means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion,’” Biestek, 139 S. Ct. at 1154, we find that substantial evidence supported the ALJ’s findings in this case. Therefore, for the

reasons set forth below, we will affirm the decision of the Commissioner denying this claim. II. Statement of Facts and of the Case

A. Background

The administrative record of the plaintiff’s disability application reveals the following essential facts: On July 30, 2020, Mirsad Hajdarevic filed a Title II application for a period of disability and disability insurance benefits, alleging disability beginning December 9, 2019. (Tr. 147). According to Hajdarevic, he was completely disabled due to the combined effects of chronic back pain, bulging disc in lower back due to work-related injury, and right-hand fracture due to work-related

3 injury. (Tr. 105). Hajdarevic was born on September 2, 1968, and was fifty-one years old at the time of the alleged onset of his disability, making him an individual closely

approaching advanced age under the Commissioner’s regulations. (Tr. 104). He has a high school education and worked for over fifteen years as a crane operator for Frog Switch & Manufacturing Company in Carlisle, Pennsylvania. (Tr. 410).

The plaintiff’s disability application was denied at the administrative and hearing levels before being remanded by the Appeals Council on September 26, 2022. (Tr. 167-72). The ALJ then conducted a rehearing on September 21, 2021, after which he again issued a decision denying Hajdarevic’s disability claim.

B. The Clinical Record The longitudinal medical record in this case demonstrates that Hajdarevic’s orthopedic impairments and chronic pain resulted from a work-related injury he

sustained in December 2019 when he fell from a ladder. (Tr. 552). He reported to Pinnacle Health All Better Care one week later, on December 16, 2019, complaining of pain in his left elbow, right thumb, left knee, and his middle and lower back. (Id.) X-rays were negative for any fracture of dislocation of the hand, knee, or spine, (Tr.

555-57), and the examination revealed a normal gait but tenderness, swelling, and muscle tightness in the lumbar spine, limited range of motion with pain, tenderness and swelling in the elbow, left knee tenderness but full range of motion with some

4 discomfort. (Tr. 553). He was diagnosed with dorsalgia, unspecified (back pain), left knee pain, and a right thumb sprain and prescribed prednisone and a thumb splint.

(Tr. 554). Physical therapy was recommended. (Id.) At a follow up appointment one week later he continued to report right hand pain and ongoing back pain, but the examination showed he was able to bear weight on his left knee and walk without

difficulty or antalgia despite some left knee tenderness. (Tr. 561). He was referred for physical therapy and prescribed a muscle relaxer for his back. (Tr. 562). Hajdarevic completed a course of fifty-five physical therapy treatments between January and May 2020. (Tr. 548-71, 665-898). Although he consistently

reported ongoing pain in his lower back and left knee, he made progress in increasing his flexibility and lifting tolerance. (Tr. 592, 616). The goal was to get Hajdarevic back to work at his moderate-to-heavy exertion level job as a crane operator, since

it was repeatedly noted that, although he had been approved for light work, he had been unable to return to work because his employer did not have light duty work and there were layoffs due to COVID-19. (Tr. 563, 567, 594, 960, 980). His initial evaluation showed decreased range of motion in his spine, lower back pain with

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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)
Dickinson v. Zurko
527 U.S. 150 (Supreme Court, 1999)
Kacee Chandler v. Commissioner Social Security
667 F.3d 356 (Third Circuit, 2011)

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