King v. Dudek

CourtDistrict Court, S.D. West Virginia
DecidedMarch 28, 2025
Docket3:24-cv-00606
StatusUnknown

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

Bluebook
King v. Dudek, (S.D.W. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA

HUNTINGTON DIVISION SANDRA K., Plaintiff, vs. CIVIL ACTION NO. 3:24-CV-00606 LELAND DUDEK, Acting Commissioner Of Social Security,

Defendant. PROPOSED FINDINGS AND RECOMMENDATION This is an action seeking review of the final decision of the Acting Commissioner of Social Security denying the Plaintiff’s application for Disability Insurance Benefits (DIB) under Title II of the Social Security Act, 42 U.S.C. §§ 401-433. By Order entered October 25, 2024 (ECF No. 2), this case was referred to the undersigned United States Magistrate Judge to consider the pleadings and evidence, and to submit proposed findings of fact and recommendations for disposition pursuant to 28 U.S.C. § 636(b)(1)(B). Presently pending before the Court are the Plaintiff’s Brief in Support of Complaint and the Acting Commissioner’s (hereinafter “Commissioner”) Brief in Support of Defendant’s Decision. (ECF Nos. 8, 9) Having fully considered the record and the arguments of the parties, the undersigned respectfully RECOMMENDS that the United States District Judge DENY the Plaintiff’s request for reversal and entry of an award for benefits or remand for further proceedings (ECF No. 8), GRANT the Commissioner’s request to affirm the final decision (ECF No. 9); AFFIRM the final

1 decision of the Commissioner; and DISMISS this matter from this Court’s docket for the reasons stated infra. Procedural History The Plaintiff protectively filed her application for DIB on August 10, 2020 alleging

disability beginning July 15, 2020 due to coronary artery disease, quadruple bypass surgery, neuroendocrine cancer, malignant carcinoid tumors “stage 3”, anemia requiring iron/blood transfusions, meningioma brain tumor, thyroid nodule, chronic back and neck pain “ruptured/enlarged disc”, and multiple inguinal hernias with surgery. (Tr. at 86, 255) Her claim was initially denied on February 5, 2021 and upon reconsideration on April 8, 2022 (Tr. at 86, 127-144, 146-155). Thereafter, the Plaintiff filed a written request for hearing on May 20, 2022 (Tr. at 86, 181-182). An administrative hearing was held on August 22, 2023 before the Honorable Christina Hajjar, Administrative Law Judge (“ALJ”) (Tr. at 106-126). On October 4, 2023, the ALJ entered an unfavorable decision (Tr. at 83-105). On August 26, 2024, the Appeals Council denied the

Plaintiff’s Request for Review (Tr. at 229-231), thus, the ALJ’s decision became the final decision of the Commissioner (Tr. at 1-7). On October 25, 2024, the Plaintiff brought the present action seeking judicial review of the administrative decision pursuant to 42 U.S.C. § 405(g). (ECF No. 1) The Commissioner filed a Transcript of the Administrative Proceedings. (ECF No. 5) Subsequently, the Plaintiff filed her Brief in Support of Complaint (ECF No. 8); in response, the Commissioner filed a Brief in Support of Defendant’s Decision (ECF No. 9), to which the Plaintiff filed her Reply Brief (ECF No. 10). Consequently, this matter is fully briefed and ready for resolution.

2 Plaintiff’s Background The Plaintiff was 55 years old as of the alleged onset date and therefore defined as a “person of advanced age” during the underlying proceedings. See 20 C.F.R. § 404.1563(e). (Tr. at 127) She has a high school education, and last worked on July 15, 2020 as a surgery scheduler/medical

scribe. (Tr. at 255-256). Standard Under 42 U.S.C. § 423(d)(5) and § 1382c(a)(3)(H)(i), a claimant for disability benefits has the burden of proving a disability. See Blalock v. Richardson, 483 F.2d 773, 774 (4th Cir. 1972). A disability is defined as the “inability to engage in any substantial gainful activity by reason of any medically determinable impairment which can be expected to last for a continuous period of not less than 12 months . . . .” 42 U.S.C. § 423(d)(1)(A). The Social Security Regulations establish a “sequential evaluation” for the adjudication of disability claims. 20 C.F.R. § 404.1520. If an individual is found “not disabled” at any step, further inquiry is unnecessary. Id. § 404.1520(a). The first inquiry under the sequence is whether a claimant is currently engaged in substantial gainful employment. Id. § 404.1520(b). If the claimant is not, the second inquiry is whether the claimant suffers from a severe impairment. Id. §

404.1520(c). If a severe impairment is present, the third inquiry is whether such impairment meets or equals any of the impairments listed in Appendix 1 to Subpart P of the Administrative Regulations No. 4. Id. § 404.1520(d). If it does, the claimant is found disabled and awarded benefits. Id. If it does not, the fourth inquiry is whether the claimant’s impairments prevent the performance of past relevant work. Id. § 404.1520(f). By satisfying inquiry four, the claimant

3 establishes a prima facie case of disability. Hall v. Harris, 658 F.2d 260, 264 (4th Cir. 1981). The burden then shifts to the Commissioner, McLain v. Schweiker, 715 F.2d 866, 868-69 (4th Cir. 1983), and leads to the fifth and final inquiry: whether the claimant is able to perform other forms of substantial gainful activity, considering claimant’s remaining physical and mental capacities and claimant’s age, education and prior work experience. Id. § 404.1520(g). The Commissioner must show two things: (1) that the claimant, considering claimant’s age, education, work experience, skills and physical shortcomings, has the capacity to perform an alternative job, and (2) that this specific job exists in the national economy. McLamore v. Weinberger, 538 F.2d 572, 574 (4th Cir. 1976).

When a claimant alleges a mental impairment, the Social Security Administration (“SSA”) “must follow a special technique at every level in the administrative review process.” 20 C.F.R. § 404.1520a(a). First, the SSA evaluates the claimant’s pertinent symptoms, signs and laboratory findings to determine whether the claimant has a medically determinable mental impairment and documents its findings if the claimant is determined to have such an impairment. Second, the SSA rates and documents the degree of functional limitation resulting from the impairment according to criteria as specified in Section 404.1520a(c): (c) Rating the degree of functional limitation. (1) Assessment of functional limitations is a complex and highly individualized process that requires us to consider multiple issues and all relevant evidence to obtain a longitudinal picture of your overall degree of functional limitation.

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King v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/king-v-dudek-wvsd-2025.