Lamberth v. Kijakazi

CourtDistrict Court, M.D. Pennsylvania
DecidedJanuary 31, 2025
Docket4:23-cv-00900
StatusUnknown

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

Bluebook
Lamberth v. Kijakazi, (M.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA MELISSA L.,1 ) CIVIL ACTION NO. 4:23-CV-900 Plaintiff ) ) v. ) ) (ARBUCKLE, M.J.) MICHELLE KING,2 Acting ) Commissioner of the Social Security, ) Defendant )

MEMORANDUM OPINION I. INTRODUCTION Melissa L. is an adult who lives in the Middle District of Pennsylvania. She seeks judicial review of the final decision of the Commissioner of Social Security (“Commissioner”) denying her applications for disability insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. Jurisdiction is conferred on this Court pursuant to 42 U.S.C. §405(g). This matter is before me upon consent of the parties pursuant to 28 U.S.C. § 636(c) and Rule 73 of the Federal Rules of Civil Procedure. (Doc. 7). After reviewing the parties’ briefs, the Commissioner’s final decision, and the relevant

1 We adopt the recommendation of the Committee on Court Administration and Case Management of the Judicial Conference of the United States that federal courts refer to social security plaintiffs by their first name and last initial. 2 Michelle King became the Acting Commissioner of Social Security on January 20, 2025. She is automatically substituted as a party pursuant to Fed. R. Civ. P. 25(d); see also 42 U.S.C. § 405(g). Page 1 of 18 portions of the certified administrative transcript, we find the Commissioner's final decision is not supported by substantial evidence. Accordingly, this matter will be

remanded to the Commissioner for further proceedings pursuant to sentence four of 42 U.S.C. § 405(g). II. BACKGROUND AND PROCEDURAL HISTORY On December 31, 2019, Plaintiff protectively filed applications for disability

insurance benefits and supplemental security income under Titles II and XVI of the Social Security Act. (Admin. Tr. 86; Doc. 9-3, p. 15). In these applications, Plaintiff alleged she became disabled on December 26, 2019, when she was forty-nine years

old, due to the following conditions: Attention Deficit Hyperactivity Disorder; high blood pressure; Type 1 Diabetes; anxiety, and depression. (Admin. Tr. 73; Doc. 9- 3, p. 2); (Admin. Tr. 86; Doc. 9-3, p. 15). Plaintiff alleges that the combination of these conditions affects her ability to lift, squat, bend, kneel, hear, follow

instructions, and deal with people and stressful situations, pay attention, and sit still. (Admin. Tr. 355; Doc. 9-6, p. 80). Plaintiff’s conditions also affect her memory. Id. Plaintiff graduated high school. (Admin. Tr. 27; Doc. 9-2, p. 28). Before the onset

of her impairments, Plaintiff worked as a cashier at Walmart for approximately fourteen years. (Admin. Tr. 136; Doc. 9-3, p. 65). On October 16, 2019, Plaintiff’s applications were denied at the initial level of administrative review. (Admin. Tr. 141-149; Doc. 9-4, pp. 2-10). On January 21,

Page 2 of 18 2021, Plaintiff’s application was denied on reconsideration. (Admin. Tr. 154-155; Doc. 9-4, pp. 15-16). On March 21, 2021, Plaintiff requested an administrative

hearing. (Admin. Tr. 174; Doc. 9-4, p. 35). On November 15, 2021, Plaintiff and her counsel participated in a telephone hearing before Administrative Law Judge Charles Dominick. (Admin. Tr. 36; Doc.

9-2, p. 37). On February 11, 2022, the ALJ issued a decision denying Plaintiff’s application for benefits. (Admin. Tr. 13; Doc. 9-2, p. 14). On April 16, 2022, Plaintiff requested that the Appeals Council of the Office of Disability Adjudication and Review (“Appeals Council”) review the ALJ’s decision. (Admin. Tr. 238; Doc. 9-4,

p. 99). On September 15, 2022, the Appeals Council denied Plaintiff’s request for review. (Admin. Tr. 1; Doc. 9-2, p. 2). On June 1, 2023, Plaintiff filed a complaint in federal court requesting judicial

review of the Commissioner’s final decision. (Doc. 1). In the complaint, Plaintiff alleges that the ALJ’s decision denying her applications for benefits is not supported by substantial evidence, and improperly applies the law. (Doc. 1). As relief, Plaintiff requests that the court reverse and set aside the administrative decision or in the

alternative remand Plaintiff’s case for a new hearing. (Doc. 1, pp. 1-2). On July 31, 2023, the Commissioner filed an answer. (Doc. 8). In the answer, the Commissioner maintains that the decision denying Plaintiff’s application was

made in accordance with the law and is supported by substantial evidence. (Doc. 8, Page 3 of 18 ¶ 7). Along with his answer, the Commissioner filed a certified transcript of the administrative record. (Doc. 9).

Plaintiff’s Brief (Doc. 10), the Commissioner’s Brief (Doc. 12), and Plaintiff’s reply (Doc. 13) have been filed. This matter is now ready to decide. III. LEGAL STANDARDS Before looking at the merits of this case, it is helpful to restate the legal

principles governing Social Security Appeals, including the standard for substantial evidence review, and the guidelines for the ALJ’s application of the five-step sequential evaluation process. We will also discuss the framework an ALJ uses to

evaluate a claimant’s symptoms. A. SUBSTANTIAL EVIDENCE REVIEW – THE ROLE OF THIS COURT A district court’s review of ALJ decisions in social security cases is limited to the question of whether the findings of the final decision-maker are supported by

substantial evidence in the record.3 Substantial evidence “does not mean a large or considerable amount of evidence, but rather such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”4 Substantial evidence is less than a preponderance of the evidence but more than a mere scintilla.5 A single

3 See 42 U.S.C. § 405(g); Johnson v. Comm’r of Soc. Sec., 529 F.3d 198, 200 (3d Cir. 2008); Ficca v. Astrue, 901 F. Supp. 2d 533, 536 (M.D. Pa. 2012). 4 Pierce v. Underwood, 487 U.S. 552, 565 (1988). 5 Richardson v. Perales, 402 U.S. 389, 401 (1971). Page 4 of 18 piece of evidence is not substantial if the ALJ ignores countervailing evidence or fails to resolve a conflict in the record.6 In an adequately developed factual record,

substantial evidence may be “something less than the weight of the evidence, and the possibility of drawing two inconsistent conclusions from the evidence does not prevent [the ALJ’s decision] from being supported by substantial evidence.”7 When

determining if the Commissioner’s decision is supported by substantial evidence under sentence four of 42 U.S.C. § 405(g), the court may consider any evidence that was in the record that was made before the ALJ.8 The Supreme Court has underscored the limited scope of district court review

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