Juan R. López-Capllonch v. Commissioner of Social Security

District Court, D. Puerto Rico·Decided July 31, 2026·No. 3:25-cv-01001·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF PUERTO RICO

JUAN R. LÓPEZ-CAPLLONCH,

Plaintiff,

v. CIVIL NO.: 25-1001 (MEL)

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

OPINION AND ORDER I. PROCEDURAL AND FACTUAL BACKGROUND Pending before the Court is Mr. Juan R. López-Capllonch’s (“Plaintiff”) complaint challenging the decision of the Commissioner of Social Security (the “Commissioner”) denying his application for disability benefits under the Social Security Act. ECF No. 1. On September 2, 2020, Plaintiff filed an application for disability insurance benefits. Tr. 401-07. Plaintiff alleged that he initially became unable to work due to disability on September 11, 2016 (the “onset date”). Tr. 170. Prior to the onset date, Plaintiff had no past relevant work.1 Tr. 36. Plaintiff’s claim was initially denied on February 5, 2021, and also denied upon reconsideration on April 8, 2021. Tr. 191, 212. Thereafter, at Plaintiff’s request, a hearing was conducted on July 24, 2023, before an Administrative Law Judge (the “ALJ”). Tr. 39-52. On August 24, 2023, after the hearing, the ALJ denied Plaintiff’s disability and benefits claim request. Tr. 23-34. Plaintiff filed a Request for Review of the ALJ’s decision which was denied by the Appeals Council on November 7, 2024. Tr. 1. This determination rendered the ALJ’s decision the final decision of the Commissioner, subject

1 The opinion of the Administrative Law Judge determine that Plaintiff had no past relevant work. Tr. 32. This finding is not contested. Other documents contained in the transcript note that prior to 2016, the Plaintiff worked as a salesman of flowers, fruits and vegetables. See Tr. 44, 113, 160. to judicial review. Tr. 1-5. Plaintiff then filed a civil complaint in this Court on January 2, 2025. ECF No. 1. Both parties have filed supporting memoranda. ECF Nos. 13, 14. II. LEGAL STANDARD A. Standard of Review Once the Commissioner has rendered a final determination on an application for disability benefits, a district court “shall have power to enter, upon the pleadings and transcript of the record,

a judgment affirming, modifying, or reversing [that decision], with or without remanding the cause for a rehearing.” 42 U.S.C. § 405(g). The court’s review is limited to determining whether the ALJ employed the proper legal standards and whether her factual findings were founded upon sufficient evidence. Specifically, the court “must examine the record and uphold a final decision of the Commissioner denying benefits, unless the decision is based on a faulty legal thesis or factual error.” López-Vargas v. Comm’r of Soc. Sec., 518 F. Supp. 2d 333, 335 (D.P.R. 2007) (citing Manso- Pizarro v. Sec’y of Health & Human Servs., 76 F.3d 15, 16 (1st Cir. 1996) (per curiam)). Additionally, “[t]he findings of the Commissioner . . . as to any fact, if supported by substantial evidence, shall be conclusive.” 42 U.S.C. § 405(g). Substantial evidence is “such relevant

evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971). The standard requires “‘more than a mere scintilla of evidence but may be somewhat less than a preponderance’ of the evidence.” Ginsburg v. Richardson, 436 F.2d 1146, 1148 (3d Cir. 1971) (quoting Laws v. Celebrezze, 368 F.2d 640, 642 (4th Cir. 1966)). While the Commissioner’s findings of fact are conclusive when they are supported by substantial evidence, they are “not conclusive when derived by ignoring evidence, misapplying the law, or judging matters entrusted to experts.” Nguyen v. Chater, 172 F.3d 31, 35 (1st Cir. 1999) (per curiam) (citing Da Rosa v. Sec’y of Health & Human Servs., 803 F.2d 24, 26 (1st Cir. 1986) (per curiam); Ortiz v. Sec’y of Health & Human Servs., 955 F.2d 765, 769 (1st Cir. 1991) (per curiam)). Moreover, a determination of substantiality must be made based on the record as a whole. See Ortiz, 955 F.2d at 769 (citing Rodríguez v. Sec’y of Health & Human Servs., 647 F.2d 218, 222 (1st Cir. 1981)). However, “[i]t is the responsibility of the [ALJ] to determine issues of credibility and to draw inferences from the record evidence.” Id. Therefore, the court “must affirm the [Commissioner’s] resolution, even if the record arguably could justify a different conclusion, so long as it is supported by substantial evidence.” Rodríguez Pagán v. Sec’y of Health & Human

Servs., 819 F.2d 1, 3 (1st Cir. 1987) (per curiam). B. Disability under the Social Security Act To establish entitlement to disability benefits, a plaintiff bears the burden of proving that she is disabled within the meaning of the Social Security Act. See Bowen v. Yuckert, 482 U.S. 137, 146 n.5, 146–47 (1987). An individual is deemed to be disabled under the Social Security Act if she is unable “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). Claims for disability benefits are evaluated according to a five-step sequential process. 20

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