Kampf v. Dudek

CourtDistrict Court, E.D. Virginia
DecidedMarch 27, 2025
Docket3:23-cv-00821
StatusUnknown

This text of Kampf v. Dudek (Kampf v. Dudek) 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
Kampf v. Dudek, (E.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

L. BRET K.,1 ) ) Plaintiff, ) ) v. ) Civil No. 3:23-cv-00821-SLS ) LELAND DUDEK,2 ) Acting Commissioner of Social Security, ) ) Defendant. ) _______________________________________)

MEMORANDUM OPINION In this action, Plaintiff L. Bret K. seeks review of the Commissioner of the Social Security Administration’s (“SSA”) decision to deny his Title II application for disability insurance benefits. This matter comes before the Court on cross-motions for summary judgment, which have been fully briefed, making this matter ripe for review. (ECF Nos. 13, 14, 17.) The Court exercises jurisdiction with the consent of the parties pursuant to 28 U.S.C. § 636(c)(1) (ECF Nos. 3, 18, 19) and pursuant to 42 U.S.C. § 405(g). Plaintiff moves the Court to reverse the Commissioner’s decision denying him social security benefits and remand for a de novo hearing and new decision. (Plaintiff’s Memorandum of Law in Support of a Motion for Summary Judgment (ECF No. 14) (“Pl.’s Mem.”) at 19 .) As the basis for such relief, Plaintiff argues that the Administrative Law Judge’s (“ALJ”) residual

1 The Committee on Court Administration and Case Management of the Judicial Conference of the United States has recommended that federal courts refer to claimants by their first names and last initials in social security cases. 2 Leland Dudek became the Acting Commissioner of Social Security in February 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, he has been substituted for the former Commissioner as Defendant in this action. No further action need be taken. 42 U.S.C. § 405(g). functional capacity (“RFC”) determination is not supported by substantial evidence because he: (1) erred in evaluating Plaintiff’s subjective complaints; and (2) improperly evaluated the medical opinions of Philip Hatfield, Ph.D. (“Dr. Hatfield”) and Geunjae Lee, PMHNP (“PMHNP Lee”). (Pl.’s Mem. at 11-18.)

In response, the Commissioner argues that the ALJ properly considered and analyzed Plaintiff’s subjective complaints as well as Dr. Hatfield and PMHNP Lee’s medical opinions in accordance with the regulations. (Defendant’s Motion for Summary Judgment and Brief in Support Thereof (ECF No. 17) (“Def.’s Br.”) at 22-30.) Therefore, the Commissioner asks the Court to affirm the decision. (Def.’s Br. at 30.) For the reasons set forth below, the Court finds that the ALJ’s consideration of Plaintiff’s subjective complaints and the medical opinion evidence comports with applicable legal standards and that substantial evidence supports the ALJ’s RFC determination. Therefore, the Court will DENY Plaintiff’s Motion for Summary Judgment (ECF No. 13), GRANT the Commissioner’s Motion for Summary Judgment (ECF No. 17), and AFFIRM the final decision of the

Commissioner. I. PROCEDURAL HISTORY On July 22, 2021, Plaintiff filed a Title II application for disability insurance benefits, alleging disability beginning on February 16, 2021. (Administrative Record (“R.”) at 85.)3 In his application, Plaintiff alleged that he suffered from a back injury, migraines, sleep apnea, Post- Traumatic Stress Disorder (“PTSD”), cognitive difficulties, and anxiety. (R. at 73.) The SSA

3 The administrative record in this case remains filed under seal, pursuant to E.D. Va. Loc. R. 5 and 7(C). In accordance with these rules, the Court will exclude personal identifiers from this Memorandum Opinion. The Court will further restrict its discussion of Plaintiff’s medical information to the extent necessary to result in a proper analysis of the case. denied Plaintiff’s claims initially and again upon reconsideration. (R. at 104, 110.) Plaintiff requested a hearing before an ALJ, and one was held on June 1, 2023. (R. at 42-72, 114-15.) On July 10, 2023, the ALJ issued a written decision, finding Plaintiff not disabled under the Social Security Act (“the Act”). (R. at 17-34.) On October 25, 2023, the SSA Appeals Council

denied Plaintiff’s request for review, making the ALJ’s decision the final decision of the Commissioner. (R. at 1-3.) Plaintiff now seeks judicial review pursuant to 42 U.S.C. § 405(g). II. STANDARD OF REVIEW 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. . . .” Id. § 423(d)(2)(A). SSA regulations set forth a five-step process to determine whether an individual is disabled. 20 C.F.R. § 404.1520(a)(4); see Mascio v. Colvin, 780 F.3d 632, 634-35 (4th Cir. 2015) (describing the ALJ’s five-step sequential evaluation). At step one, the ALJ reviews the claimant’s current work activity to determine if he or she has been participating in substantial gainful activity. 20 C.F.R. § 404.1520(a)(4)(i). At step two, the ALJ asks whether the claimant’s medical impairments meet the regulations’ severity and duration requirements. Id. § 404.1520(a)(4)(ii). At step three, the ALJ determines whether the medical impairments meet or equal an impairment listed in the regulations. Id. § 404.1520(a)(4)(iii). Between steps three and four, the ALJ determines the claimant’s RFC, which accounts for the most that the claimant can do despite his or her impairments. Id. § 404.1545(a). At step four, the ALJ assesses whether the claimant can perform his or her past employment given his or her RFC. Id. § 404.1520(a)(4)(iv). The burden of proof remains with the claimant

through step four of the analysis, and the claimant must prove that his or her limitations preclude the claimant from performing his or her past relevant work. See Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987); Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012). If such past work can be performed, then benefits will not be awarded, and the analysis ends. See 20 C.F.R. § 404.1520(e). However, if the claimant cannot perform his or her past work, the analysis proceeds to step five, and the burden then shifts to the Commissioner to show that the claimant can perform other work that is available in the national economy. See id. § 404.1520(a)(4)(v). The Commissioner usually offers this evidence through the testimony of a vocational expert. See Mascio, 780 F.3d at 635.

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