Howatt v. Commissioner of Social Security

CourtDistrict Court, W.D. New York
DecidedSeptember 30, 2024
Docket1:23-cv-00833
StatusUnknown

This text of Howatt v. Commissioner of Social Security (Howatt v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Howatt v. Commissioner of Social Security, (W.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK ______________________________________

ELIZABETH H.,

Plaintiff,

v. DECISION AND ORDER

23-CV-833S COMMISSIONER OF SOCIAL SECURITY,

Defendant. ______________________________________

1. Plaintiff Elizabeth H.1 brings this action, pursuant to the Social Security Act (“the Act”), seeking review of the final decision of the Commissioner of Social Security that denied her applications for disability insurance benefits and supplemental security income under Titles II and XVI of the Act. (Docket No. 1.) This Court has jurisdiction over this action under 42 U.S.C. § 405(g). 2. Plaintiff protectively filed her applications with the Social Security Administration on September 10, 2020. Plaintiff alleged disability beginning on January 14, 2020, initially due to major depressive disorder, generalized anxiety disorder, post-traumatic stress disorder (“PTSD”), borderline personality disorder, post-partum vascular disease, headaches, and urge incontinence. Plaintiff’s applications were denied and she thereafter requested a hearing before an administrative law judge (“ALJ”). 3. On April 20, 2022, ALJ Victoria Ferrer held a telephonic hearing due to COVID-19 pandemic at which Plaintiff—represented by counsel—and Vocational Expert

1 In accordance with this Court’s Standing Order of November 18, 2020, and consistent with guidance from the Committee on Court Administration and Case Management of the Judicial Conference of the United States, this Decision and Order will identify Plaintiff by first name and last initial. Dale Pasculli appeared and testified. (R.2 at 15, 42-95.) At the time of the hearing, Plaintiff was a 31-year-old woman with a high school education and past work experience as a collection clerk, order clerk, and laborer-stores. (R. at 33.) 4. The ALJ considered the case de novo and, on June 1, 2022, issued a written

decision denying Plaintiff’s applications for benefits and finding that Plaintiff could perform all exertional levels of work (R. at 15, 22-23). After the Appeals Council denied Plaintiff’s request to review the ALJ’s decision, she filed her action challenging the Commissioner’s final decision.3 (Docket No. 1.) 5. Both parties moved for judgment on the pleadings under Rule 12(c) of the Federal Rules of Civil Procedure. (Docket Nos. 8, 10.) Plaintiff filed her Response on January 31, 2024 (Docket No. 11), declaring that a reply was not necessary (id. at 1). This Court then took the Motions under advisement without oral argument. For the reasons that follow, Plaintiff’s Motion will be denied and Defendant’s Motion will be granted.

6. A court reviewing a denial of disability benefits may not determine de novo whether an individual is disabled. See 42 U.S.C. §§ 405(g), 1383(c)(3); Wagner v. Sec’y of Health & Human Servs., 906 F.2d 856, 860 (2d Cir. 1990). Rather, the Commissioner’s determination will be reversed only if it is not supported by substantial evidence or there has been a legal error. See Grey v. Heckler, 721 F.2d 41, 46 (2d Cir. 1983); Marcus v. Califano, 615 F.2d 23, 27 (2d Cir. 1979). Substantial evidence is that which amounts to “more than a mere scintilla,” and it has been defined as “such relevant evidence as a

2 Citations to the underlying administrative record are designated as “R.”

3 The ALJ’s June 1, 2022, decision became the Commissioner’s final decision when the Appeals Council denied Plaintiff’s request for review. reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401, 91 S. Ct. 1420, 26 L. Ed. 2d 842 (1971). Where evidence is deemed susceptible to more than one rational interpretation, the Commissioner’s conclusion must be upheld. See Rutherford v. Schweiker, 685 F.2d 60, 62 (2d Cir. 1982).

7. “To determine on appeal whether an ALJ’s findings are supported by substantial evidence, a reviewing court considers the whole record, examining the evidence from both sides, because an analysis of the substantiality of the evidence must also include that which detracts from its weight.” Williams ex rel. Williams v. Bowen, 859 F.2d 255, 258 (2d Cir. 1988). If supported by substantial evidence, the Commissioner’s finding must be sustained “even where substantial evidence may support the plaintiff’s position and despite that the court’s independent analysis of the evidence may differ from the [Commissioner’s].” Rosado v. Sullivan, 805 F. Supp. 147, 153 (S.D.N.Y. 1992). In other words, this Court must afford the Commissioner’s determination considerable deference and will not substitute “its own judgment for that of the

[Commissioner], even if it might justifiably have reached a different result upon a de novo review.” Valente v. Sec’y of Health & Human Servs., 733 F.2d 1037, 1041 (2d Cir. 1984). 8. The Commissioner has established a five-step sequential evaluation process to determine whether an individual is disabled under the Act. See 20 C.F.R. §§ 404.1520, 416.920. The Supreme Court of the United States recognized the validity of this analysis in Bowen v. Yuckert, and it remains the proper approach for analyzing whether a claimant is disabled. 482 U.S. 137, 140-42, 107 S. Ct. 2287, 96 L. Ed. 2d 119 (1987). 9. The five-step process is as follows: First, the [Commissioner] considers whether the claimant is currently engaged in substantial gainful activity. If [s]he is not, the [Commissioner] next considers whether the claimant has a “severe impairment” which significantly limits [her] physical or mental ability to do basic work activities. If the claimant suffers such an impairment, the third inquiry is whether, based solely on medical evidence, the claimant has an impairment which is listed in Appendix 1 of the regulations. If the claimant has such an impairment, the [Commissioner] will consider [her] disabled without considering vocational factors such as age, education, and work experience; the [Commissioner] presumes that a claimant who is afflicted with a “listed” impairment is unable to perform substantial gainful activity. Assuming the claimant does not have a listed impairment, the fourth inquiry is whether, despite the claimant’s severe impairment, [s]he has the residual functional capacity to perform [her] past work. Finally, if the claimant is unable to perform [her] past work, the [Commissioner] then determines whether there is other work which the claimant could perform.

Berry v. Schweiker, 675 F.2d 464, 467 (2d Cir. 1982) (per curiam) (quotations in original); see also 20 C.F.R.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Heckler v. Campbell
461 U.S. 458 (Supreme Court, 1983)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Ferraris v. Heckler
728 F.2d 582 (Second Circuit, 1984)
Williams v. Bowen
859 F.2d 255 (Second Circuit, 1988)
Zabala v. Astrue
595 F.3d 402 (Second Circuit, 2010)
Rosado v. Sullivan
805 F. Supp. 147 (S.D. New York, 1992)
Washburn v. Colvin
286 F. Supp. 3d 561 (W.D. New York, 2017)
Jordan v. Commissioner of Social Security
142 F. App'x 542 (Second Circuit, 2005)

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Howatt v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/howatt-v-commissioner-of-social-security-nywd-2024.