HAYNES v. COMMISSIONER OF SOCIAL SECURITY

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 19, 2025
Docket2:24-cv-00586
StatusUnknown

This text of HAYNES v. COMMISSIONER OF SOCIAL SECURITY (HAYNES v. COMMISSIONER OF SOCIAL SECURITY) 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
HAYNES v. COMMISSIONER OF SOCIAL SECURITY, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

TWILA H.1, : Plaintiff, : CIVIL ACTION v. : No. 24-586 : COMMISSIONER OF : SOCIAL SECURITY, : Defendant. :

MEMORANDUM

JOSÉ RAÚL ARTEAGA March 19, 2025 United States Magistrate Judge2

The Commissioner of the Social Security Administration, through an Administrative Law Judge (“ALJ”), denied, in part, Twila H.’s application for Supplemental Security Income (“SSI”) under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381-13833, finding she was not disabled from December 17, 2014, through January 17, 2021. (Tr. 21-22.) Twila H., who is self-represented, seeks judicial review of the final

1 Twila H. is referred to solely by her first name and last initial in accordance with this Court’s standing order addressing party identification in social security cases. See Standing Order, In re: Party Identification in Social Security Cases (E.D. Pa. June 10, 2024), https://www.paed.uscourts.gov/sites/paed/files/documents/locrules/standord/SO_ pty-id-ss.pdf (last visited Mar. 4, 2025).

2 The parties have consented to the jurisdiction of a United States Magistrate Judge to conduct all proceedings, including the entry of a final judgment, pursuant to 28 U.S.C. § 636(c). (ECF 9.)

3 42 U.S.C. § 1383(c)(3) renders the judicial review provisions of 42 U.S.C. § 405(g) fully applicable to claims for SSI. administrative decision pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3) and asks the Court to reverse and remand the Commissioner’s decision.

After careful review of the record, Twila H.’s request for review is DENIED, and the Commissioner’s decision is AFFIRMED. I. BACKGROUND Twila H. filed her application for SSI on December 17, 2014, alleging an August 28, 2014 disability onset date,4 based on pain in her right shoulder and right wrist, right arm pain, back pain, and difficulty breathing. (Tr. 236-37, 676.) Initially, her claim was denied,

and she timely requested a hearing. (Tr. 292-95, 296-98.) ALJ Jonathan L. Wesner held one on November 7, 2017.5 (Tr. 195-227.) On March 13, 2018, he found Twila H. not disabled under the Social Security Act. (Tr. 242-54.) She requested Appeals Council review of ALJ Wesner’s decision, and in January 2020, the Appeals Council remanded the matter for further evaluation of Twila H.’s residual functional capacity (“RFC”) and

symptoms. (Tr. 255-58, 369-70.)

4 Although supplemental security income is not payable prior to the month following the month in which the application was filed, 20 C.F.R. § 416.335, the ALJ considered Twila H.’s “complete medical history” in evaluating her claims. See 20 C.F.R. § 416.912(d).

5 ALJ Wesner also held a hearing on July 11, 2017, but it was postponed because Twila H.’s attorney at the time, Michael J. Graves, Jr., Esquire failed to appear. (Tr. 228- 34.) Graves also failed to appear at the November hearing and allegedly directed Twila H. not to appear as well. (Tr. 197-99.) Twila H. subsequently discharged Mr. Graves as her counsel. (Tr. 371.) ALJ Regina L. Warren held a telephonic hearing on November 24, 2020 due to the COVID-19 pandemic.6 (Tr. 138-65, 486-90.) On December 31, 2020, she found Twila H.

not disabled. (Tr. 263-76.) Twila H. sought review of her decision from the Appeals Council, which remanded the matter on September 7, 2021. (Tr. 283-89.) The Appeals Council directed ALJ Warren to: (1) clarify whether Twila H. was disabled from December 17, 2014, the date she filed her application for SSI; (2) give further consideration to Twila H.’s maximum RFC during the entire relevant period and provide “specific references” to evidence supporting assessed limitations; and (3) reconsider application of

6 ALJ Warren also held a hearing on May 19, 2020, but it was continued for the Social Security Administration to obtain updated records. (Tr. 188.) The hearing was rescheduled for August 18, 2020 but postponed again because Twila H. did not want to proceed without counsel. (Tr. 170.) In August 2020, Twila H. obtained new counsel, Allan Meltzer, Esquire, who represented her at the November 2020 hearing. (Tr. 141-42, 451-59.)

Twila H. does not argue she was denied the right to counsel in her administrative proceedings. Social Security claimants have a statutory and regulatory right to counsel at administrative hearings. Phifer ex rel. Phifer v. Comm’r of Soc. Sec., 84 F. App’x 189, 190 (3d Cir. 2003). Such claimants must be given notice of the right to counsel and may waive this right only by a knowing and intelligent waiver. Vivaritas v. Comm’r of Soc. Sec., 264 F. App’x 155, 157 (3d Cir. 2008) (citation omitted). Claimants are also permitted to “appoint any person who is not an attorney to be your representative in dealings with [the Social Security Administration].” 20 C.F.R. § 416.1505(b).

ALJ Warren discussed the right to counsel with Twila H. at the August 2020 hearing and granted her a postponement to obtain counsel. (See Tr. 168-71.) Twila H. subsequently engaged Mr. Meltzer, and he represented her at the November 2020 hearing. After he withdrew, she elected to appoint Kelly Dutton as a non-attorney representative. (See Tr. 564-65.) A claimant like Twila H. who previously obtained and dismissed counsel necessarily knows about her right to counsel (absent other circumstances such as mental limitations). (See Tr. 371.) Under these facts, Twila H. made a knowing and intelligent waiver of her right to counsel at the hearings. Regardless, Twila H. does not argue that ALJ Warren erred in finding Dutton to be a “qualified representative.” (Tr. 46, 98.) the sequential evaluation process in conjunction with Twila H.’s age under 20 C.F.R. § 416.963’s borderline age provisions and obtain supplemental evidence from a vocational

expert regarding transferable skills.7 (Tr. 21, 286.) ALJ Warren held another telephonic hearing on January 13, 2022. (Tr. 95-129.) Twila H. testified, as did the Agency’s vocational expert (“VE”) Ellen Levin. (Id.) Kelly Dutton, a qualified non-attorney representative, represented Twila H. at the hearing. (Tr. 98.) After the hearing, the ALJ ordered an independent orthopedic consultative examination of Twila H. and held the record open for submission of additional medical

records. (Tr. 128.) Twila H. underwent a consultative examination on April 18, 2022, and her representative submitted objections to the report. (Tr. 1608-35, 800-01.) ALJ Warren held a supplemental hearing on September 8, 2022 to consider the consultative examination report and Twila H.’s objections, along with late-submitted medical records, and to obtain additional VE testimony. (Tr. 43-94.) Twila H. testified, along with VE

Martin Kranitz. (Tr. 21.) Non-attorney representative Dutton represented Twila H. again at the telephonic supplemental hearing. (Tr. 45-46, 575.) On September 21, 2022, ALJ Warren found Twila H.

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HAYNES v. COMMISSIONER OF SOCIAL SECURITY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/haynes-v-commissioner-of-social-security-paed-2025.