Hardin v. Dudek

CourtDistrict Court, E.D. North Carolina
DecidedFebruary 25, 2025
Docket7:24-cv-00377
StatusUnknown

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

Bluebook
Hardin v. Dudek, (E.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA SOUTHERN DIVISION No. 7:24-CV-377-KS

JENNIFER HARDIN, ) ) Plaintiff, ) ) v. ) ) OORDER LELAND DUDEK,1 Acting ) Commissioner of Social Security ) A dministration, ) ) Defendant. )

This matter is before the court on the parties’ briefs pursuant to the Supplemental Rules for Social Security Actions under 42 U.S.C. § 405(g), the parties having consented to proceed pursuant to 28 U.S.C. § 636(c). Jennifer Hardin (“Plaintiff”) filed this action pursuant to 42 U.S.C. § 405(g) seeking judicial review of the denial of her application for a period of disability and disability insurance benefits (“DIB”). The time for responsive briefs has expired, and the pending motions are ripe for adjudication. On January 21, 2025, the court held oral argument in this matter. Having carefully reviewed the administrative record and the briefs submitted by the parties, the court affirms the Commissioner’s decision.

1 Plaintiff’s complaint names Martin O’Malley in his official capacity as Commissioner of Social Security. Leland Dudek is now Acting Commissioner of Social Security and therefore is substituted as the defendant to this action. Fed. R. Civ. P. 25(d). SSTATEMENT OF THE CASE Plaintiff applied for a period of disability and DIB on November 9, 2018, with an alleged onset date of March 1, 2013. (R. 11; 186–90; 1098.) The application was

denied initially and upon reconsideration, and a request for hearing was filed. (R. 99; 115; 127–30.) On February 24, 2020, a hearing was held before Administrative Law Judge (“ALJ”) William Diggs who issued an unfavorable decision on March 12, 2020. (R. 8–27; 51–82.) On November 17, 2020, the Appeals Council denied Plaintiff’s request for review. (R. 1–5.) At that time, the ALJ’s decision became the final decision of the Commissioner. 20 C.F.R. § 404.981. On January 20, 2021, Plaintiff initiated an action in this court, seeking judicial review of the final administrative decision

pursuant to 42 U.S.C. § 405(g). , No. 7:21-CV-6-FL (E.D.N.C. filed Jan. 20, 2021). On September 20, 2022, the court reversed and remanded the matter to the Commissioner pursuant to sentence four. , No. 7:21-CV-6- FL, ECF No. 25 (E.D.N.C. Sept. 20, 2022). Upon remand from this court, the Appeals Council remanded the matter for a new hearing and decision. (R. 1198–1200.) ALJ Adrienne Porter held a new hearing

on September 19, 2023, and issued an unfavorable decision on January 2, 2024. (R. 1095–1148.) This made the ALJ’s second decision the final decision of the Commissioner. 20 C.F.R. § 404.984(a). On April 29, 2024, Plaintiff initiated this action pursuant to 42 U.S.C. § 405(g), exercising her right to direct judicial review of the ALJ’s second unfavorable decision. 20 C.F.R. § 404.984(d) (ALJ’s decision after federal court remand is final decision of Commissioner if claimant files no exceptions and the Appeals Council does not otherwise assume jurisdiction). DDISCUSSION

I. Standard of Review The scope of judicial review of a final agency decision denying disability benefits is limited to determining whether substantial evidence supports the Commissioner’s factual findings and whether the decision was reached through the application of the correct legal standards. , 829 F.2d 514, 517 (4th Cir. 1987). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion; [i]t consists of more than a mere

scintilla of evidence but may be somewhat less than a preponderance.” , 76 F.3d 585, 589 (4th Cir. 1996) (quoting , 402 U.S. 389, 401 (1971), and , 368 F.2d 640, 642 (4th Cir. 1966)) (citations omitted) (alteration in original). “In reviewing for substantial evidence, [the court should not] undertake to re-weigh conflicting evidence, make credibility determinations, or substitute [its] judgment for that of the [Commissioner].”

, 270 F.3d 171, 176 (4th Cir. 2001) (quoting , 76 F.3d at 589) (first and second alterations in original). Rather, in conducting the “substantial evidence” inquiry, the court determines whether the Commissioner has considered all relevant evidence and sufficiently explained the weight accorded to the evidence. , 131 F.3d 438, 439–40 (4th Cir. 1997). III. Disability Determination In making a disability determination, the Commissioner utilizes a five-step evaluation process. The Commissioner asks, sequentially, whether the claimant:

(1) is engaged in substantial gainful activity; (2) has a severe impairment; (3) has an impairment that meets or equals the requirements of an impairment listed in 20 C.F.R. Part 404, Subpart P, App. 1; (4) can perform the requirements of past work; and, if not, (5) based on the claimant’s age, work experience, and residual functional capacity can adjust to other work that exists in significant numbers in the national economy. 20 C.F.R. § 404.1520(a)(4); , 174 F.3d 473, 475 n.2 (4th Cir. 1999). The burden of proof and production during the first four steps

of the inquiry rests on the claimant. , 65 F.3d 1200, 1203 (4th. Cir. 1995). At the fifth step, the burden shifts to the Commissioner to show that other work exists in the national economy that the claimant can perform. . In making this determination, the ALJ must decide “whether the claimant is able to perform other work considering both [the claimant’s residual functional capacity] and [the claimant’s] vocational capabilities (age, education, and past work experience) to

adjust to a new job.” , 658 F.2d 260, 264–65 (4th Cir. 1981). “If the Commissioner meets [this] burden, the ALJ finds the claimant not disabled and denies the application for benefits.” , 780 F.3d 632, 635 (4th Cir. 2015). IIII.

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Hardin v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hardin-v-dudek-nced-2025.