Hansard v. King

CourtDistrict Court, E.D. Virginia
DecidedJuly 23, 2025
Docket3:24-cv-00072
StatusUnknown

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

Bluebook
Hansard v. King, (E.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division ) RITA H.,! ) ) Plaintiff, ) ) v. ) Civil Action No. 3:24-cv-72—HEH ) FRANK BISIGNANO, ) Commissioner of Social Security,” ) ) Defendant. )

MEMORANDUM OPINION (Adopting Magistrate Judge’s Report and Recommendation) In this action, Plaintiff challenges the Social Security Administration’s (“SSA” or “Commissioner”) denial of her Title II application for disability insurance benefits. The matter is presently before the Court on the Report and Recommendation (“R&R”) filed pursuant to 28 U.S.C. § 636(b)(1)(B) by the Honorable Summer L. Speight, United States Magistrate Judge (the “Magistrate Judge”), on February 4, 2025. (ECF No. 17.) The Magistrate Judge’s R&R addressed the parties’ cross-motions for summary judgment (ECF Nos. 12, 14) and recommended the Court affirm the SSA’s decision. (R&R at 2.)

' The Committee on Court Administration and Case Management of the Judicial Conference of the United States has recommended that, due to significant privacy concerns in social security cases, federal courts should refer to claimants by only their first names and last initials. * Frank Bisignano became the Commissioner of Social Security on May 7, 2025. Pursuant to Federal Rule of Civil Procedure 25(d), Frank Bisignano should be substituted for Michelle King as Defendant in this suit. No further action need be taken to continue this suit by reason of the last sentence of § 405(g) of the Social Security Act, 42 U.S.C. § 405(g).

Plaintiff has filed Objections to the R&R (ECF No. 18), and the Commissioner has responded thereto (ECF No. 19). The Court will dispense with oral argument because the facts and legal contentions are fully developed, and argument would not aid the Court in its decisional process. See E.D. Va. Loc. Civ. R. 7(J). “A judge of the court shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1)(C); see also Fed. R. Civ. P. 72(b)(3); Nichols v. Colvin, 100 F. Supp. 3d 487, 497 (E.D. Va. 2015) (“[T]he objection requirement is designed to allow the district court to ‘focus on specific issues, not the report as a whole.’” (quoting United States v. Midgette, 478 F.3d 616, 621 (4th Cir. 2007))). In conducting its review, this Court “may accept, reject, or modify, in whole or in part,” the Magistrate Judge’s recommended disposition of the case. 28 U.S.C. § 636(b)(1)(C); see also Fed. R. Civ. P. 72(b)(3). I. BACKGROUND On April 27, 2020, Plaintiff applied for Social Security Disability Insurance Benefits (“DIB”) under the Social Security Act (the “Act”). Plaintiff alleged that she suffered from major depressive disorder, generalized anxiety disorder, hypertension, carpal tunnel syndrome in both hands, borderline diabetes, several issues with her right foot, a torn ligament in her right shoulder, and panic disorders. (R. at 111-12.) The SSA denied Plaintiff's claims both initially and upon reconsideration. (/d. at 108, 109.) Plaintiff then requested a hearing before an administrative law judge (“ALJ”), which took place on November 3, 2021. (/d. at 77-99, 164.) On December 1, 2021, the ALJ issued

a written opinion, finding that Plaintiff was not disabled under the Act. (/d. at 125-39.) On July 27, 2022, the SSA Appeals Council granted Plaintiffs request for review of the ALJ’s decision and remanded the case to an ALJ. (/d. at 141-42.) A hearing on remand was held on November 29, 2022. (/d. at 38-76.) The ALJ issued a written decision on August 22, 2023, again finding that Plaintiff was not disabled under the Act. (/d. at 17-30.) On December 19, 2023, the SAA Appeals Council denied Plaintiffs request for review, rendering the ALJ’s decision the final decision of the Commissioner. (/d. at 1-6.) A. The ALJ’s Five-Step Evaluation Process The Act defines a disability 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.” 42 U.S.C. § 423(d)(1)(A). An individual has a disability “only if his [or her] physical or mental impairment or impairments are of such severity that he [or she] is not only unable to do his [or her] previous work but cannot, considering his [or her] age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy... .” Jd. § 423(d)(2)(A). In making the disability determination, the ALJ followed the five-step evaluation process pursuant to SSA regulations. See 20 C.F.R. § 404.1520(a)(4); Mascio v. Colvin, 780 F.3d 632, 634 (4th Cir. 2015). At step one of the evaluation process, the ALJ found

that Plaintiff had not engaged in substantial gainful activity? since November 15, 2018. (R. at 20.) At step two, the ALJ determined that Plaintiff had the following severe impairments: (1) obesity, (2) bilateral carpal tunnel syndrome, (3) bilateral knee | osteoarthritis, (4) and right foot, ankle, and posterior tibial tendinitis. (/d.) The ALJ found that Plaintiff did not suffer from any severe mental impairments. Specifically, the AL]J considered the criteria required by regulation and concluded that Plaintiff's “medically determinable mental impairments of major depressive disorder and generalized anxiety disorder, considered singly and in combination, [did] not cause more than minimal limitation in [her] ability to perform basic mental work activities and [were] therefore non-severe.” (/d. at 21-22.) Although Plaintiff's mental impairments were not

severe, the ALJ nonetheless considered them in assessing Plaintiff's RFC. (/d.) At step three, the ALJ determined that Plaintiff did not have impairment which met or equaled a disability provided by the regulations. (/d. at 22-23); see 20 C.F.R. Part 404, Subpart P, App. 1. Based on the evidence in the record, the ALJ determined Plaintiff's residual functional capacity (“RFC”), namely that Plaintiff retained the ability to perform a range of medium work as defined in 20 C.F.R. § 404.1567(c) with the following limitations:

3 Substantial gainful activity is work that is both substantial and gainful as defined by the Agency in the C.F.R.

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Hancock v. Astrue
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Bluebook (online)
Hansard v. King, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hansard-v-king-vaed-2025.