Lamphere v. Commissioner of Social Security

CourtDistrict Court, N.D. New York
DecidedMay 5, 2025
Docket3:24-cv-00476
StatusUnknown

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

Bluebook
Lamphere v. Commissioner of Social Security, (N.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK TABITHA L.,! Plaintiff, V. 3:24-CV-476 (AJB/MJK) LELAND DUDEK, Acting Commissioner of Social Security Defendant.

HOWARD D. OLINSKY ESQ., for Plaintiff NAHID SOROOSHYARI ESQ., Special Asst. U.S. Attorney, for Defendant MITCHELL J. KATZ, U.S. Magistrate Judge TO THE HONORABLE ANTHONY J. BRINDISI, U.S. District Judge: REPORT- RECOMMENDATION Plaintiff commenced this action under the Social Security Act (42 U.S.C. § 405(g)) seeking judicial review of the Commissioner of Social Security’s final decision denying his application for benefits. Plaintiff did not consent to the jurisdiction of a Magistrate Judge (Dkt. No. 5) so the Honorable David N. Hurd, Senior U.S. District Judge, referred this matter to the Court for Report and

accordance with guidance from the Committee on Court Administration and Case Management of the Judicial Conference of the United States, which was adopted by the Northern District of New York in June 2018 to better protect personal and medical information of non- governmental parties, this Memorandum-Decision and Order will identify the plaintiff using only his first name and last initial.

Recommendation under 28 U.S.C. § 636(b) and Local Rule 72.3(d).” Both parties filed briefs (Dkts. 9, 13, 14) which the Court treats as motions under Fed. R. Civ. P. 12(c), in accordance with General Order 18. I. PROCEDURAL HISTORY On August 6, 2021, Plaintiff applied for Supplemental Security Income under Title II alleging disability beginning July 2, 2008. (T. 11).* Her claim was initially denied on November 3, 2021, and upon reconsideration on January 19, 2022. (/d.). Administrative Law Judge (“ALJ”) John Ramos held a telephonic hearing on May 16, 2023. (T. 11-24). At this hearing, non-attorney representative, Kevin Dwyer represented Plaintiff. (T. 11). Both Plaintiff and impartial vocational expert, Jeroen Walstra testified. (T. 39-56; 58-65). On July 5, 2023, the ALJ issued

an unfavorable decision. (T. 8-24). Plaintiff timely appealed by filing the operative complaint. (Dkt. 1). Il. GENERALLY APPLICABLE LAW A. Disability Standards To be considered disabled, plaintiffs seeking Disability Insurance or Supplemental Security Income benefits must establish that they are “unable to

engage in any substantial gainful activity by reason of any medically determinable

? On December 19, 2024, this case was reassigned from Senior District Judge Hurd to District Judge Brindisi. > All page references are to the Administrative Transcript (“T.”) and not the page numbers assigned by the CM/ECF pagination system.

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 twelve months ...” 42 U.S.C. § 1382c(a)(3)(A). In addition, plaintiffs’ physical or mental impairment or impairments [must be] of such severity that [they are] not only unable to do [their] previous work but cannot, considering [their] age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy, regardless of whether such work exists in the immediate area in which [they] live[], or whether a specific job vacancy exists for [them], or whether [they] would be hired if [they] applied for work. 42 U.S.C. § 1382c(a)(3)(B). The Commissioner uses a five-step process, set forth in 20 C.F.R. §§ 404.1520 and 416.920, to evaluate disability insurance and SSI disability claims. First, the [Commissioner] considers whether the claimant is currently engaged in substantial gainful activity. If [they are] not, the [Commissioner] next considers whether the claimant has a “severe impairment” which significantly limits [their] 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 meets or equals the criteria of an impairment listed in Appendix 1 of the regulations. If the claimant has such an impairment, the [Commissioner] will consider [them] disabled without considering vocational factors such as age, education, and work experience ... Assuming the claimant does not have a listed impairment, the fourth inquiry is whether, despite the claimant’s severe impairment, [they have] the residual functional capacity to perform [their] past work. Finally, if the claimant is unable to perform [their] past work, the [Commissioner] then determines whether there is other work which the claimant can perform. Berry v. Schweiker, 675 F.2d 464, 467 (2d Cir. 1982); see also 20 C.F.R. §§ 404.1520, 416.920. Plaintiffs have the burden of establishing disability at the first

four steps. See Selian v. Astrue, 708 F.3d 409, 418 (2d Cir. 2013). If they establish that their impairment prevents them from performing their past work, the burden then shifts to the Commissioner to prove the final step. Jd. B. Scope of Review When reviewing a final decision of the Commissioner, courts must determine whether the correct legal standards were applied and whether substantial evidence supported the decision. Jd. at 417; see also Brault v. Soc. Sec. Admin., Comm ’r, 683 F.3d 443, 448 (2d Cir. 2012); 42 U.S.C. § 405(g). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Zalavera v. Astrue, 697 F.3d 145, 151 (2d Cir. 2012). It must be “more than a scintilla” of evidence scattered throughout the administrative record. /d. But this standard is a very deferential standard of review “—even more

so than the ‘clearly erroneous standard.’” Brault, 683 F.3d at 448. “To determine

on appeal whether an ALJ’s findings are supported by substantial evidence, reviewing courts consider 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). However, reviewing courts may not substitute its interpretation of the administrative record for that of the Commissioner if the

record contains substantial support for the ALJ’s decision. Jd.; see also Rutherford v. Schweiker, 685 F.2d 60, 62 (2d Cir. 1982). ALJs need not explicitly analyze every piece of conflicting evidence in the record. See Mongeur v.

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