Laurie K. v. Commissioner of Social Security

CourtDistrict Court, N.D. New York
DecidedApril 21, 2026
Docket3:25-cv-00411
StatusUnknown

This text of Laurie K. v. Commissioner of Social Security (Laurie K. 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
Laurie K. v. Commissioner of Social Security, (N.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK __________________________________________________________________ Laurie K.,1 Plaintiff, v. 3:25-CV-411 (MAD/MJK)

Commissioner of Social Security, Defendant. __________________________________________________________________ Howard Olinsky, Esq., for Laurie K. Candace Brown Casey, Special Asst. U.S. Attorney, for Defendant

Mitchell J. Katz, U.S. Magistrate Judge

To the Honorable Mae A. D’Agostino, U.S. District Judge:

REPORT-RECOMMENDATION Laurie K. brought this action under the Social Security Act (42 U.S.C. § 405(g)), seeking judicial review of the Social Security Commissioner’s final decision denying her application for benefits. (Dkt. 1.). Laurie K. did not consent to the jurisdiction of a Magistrate Judge. Both parties filed briefs (Dkts. 15, 22, 23). And at the Court's request, both sides filed supplemental briefs (Dkts. 24, 26, 27). The Court heard oral argument on April 1 focused on the issue of remand for benefits

1 This Report-Recommendation will identify the plaintiff using only her first name and last initial to protect her privacy. only. Under Fed. R. Civ. P. 12(c), and in accordance with General Order 18, the Court treats these briefs as motions.

I. PROCEDURAL HISTORY On April 29, 2015, Laurie K. applied for Supplemental Security

Income (“SSI”), alleging disability beginning July 6, 2014. (T. 97, 183).2 Her application was denied on September 2, 2015, and she filed a written request for a hearing with an Administrative Law Judge

(“ALJ”). (T. 31). A hearing was held on November 13, 2017, and a decision finding Laurie K. not disabled was issued on January 17, 2018. See Laurie M.K. v. Comm’r of Soc. Sec., 3:22-CV-0947 (GTS/DEP), 2023

WL 7004934 at *1–2 (N.D.N.Y. Sept. 1, 2023), report and recommendation adopted, 2023 WL 7003931 (N.D.N.Y. Oct. 24, 2023).

The Appeals Council granted review, vacated the ALJ’s decision, and found Laurie K. not disabled. Id. at *2. Laurie K. appealed to this Court, and the Court remanded on May

15, 2020, based on a stipulation between Laurie K. and the Commissioner. Id. In the stipulations, both sides agreed that the ALJ

2 All page references are to the Administrative Transcript (“T.”), and not the page numbers assigned by the CM/ECF pagination system. All other page references are to the numbers assigned by the CM/ECF pagination system. failed to properly analyze Laurie K.’s treating physician’s opinion. Id. On remand, the case went before a different ALJ, and administrative

hearings were held on November 16, 2021, and May 9, 2022. Id. On July 7, 2022, the ALJ issued a decision finding Laurie K. not disabled. Id.

Laurie K. again appealed to this Court. Id. at *3. The Court conducted oral argument by telephone and reversed the ALJ's decision

based on the ALJ’s failure to properly analyze the opinion of treating physician Dr. Carr. Id. The Court issued an order in which it directed the Commissioner to consider the assessment of Laurie K.’s treating

physician Dr. Carr. See Id. On remand, the case went before a different ALJ, and on November 20, 2024, ALJ Gretchen Greisler held a hearing. (T. 2814–

48). On January 31, 2025, ALJ Greisler issued an unfavorable decision. (T. 2774–2800). Laurie K. again appealed to this Court. (Dkt. 1). II. GENERALLY APPLICABLE LAW

A. Disability Standards To be considered disabled, a claimant seeking DIB or SSI benefits must establish that they are “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 twelve months . . . .” 42 U.S.C. § 1382c(a)(3)(A). Additionally, the claimant’s

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) (cleaned up). The Commissioner uses a five-step process, set forth in 20 C.F.R. sections 404.1520 (for DIB) and 416.920 (for SSI), to evaluate 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) (per curiam); see Rosa v. Callahan, 168 F.3d 72, 77 (2d Cir. 1999) (quoting Berry, 675 F.2d at 467). The claimant has the burden of establishing disability at the first four steps. Berry, 675 F.2d at 467. If the claimant establishes that their impairment prevents them from performing their past work, then the burden shifts to the Commissioner to prove the fifth and final step. Id. 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. Id. 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.” Talavera v. Astrue, 697 F.3d 145, 151 (2d Cir. 2012). It must be “more than a scintilla” of evidence scattered throughout the administrative record. Id. Yet this standard is a very deferential standard of review “—

even more so than the ‘clearly erroneous standard.’” Brault, 683 F.3d at 448. “[T]o determine on appeal whether an ALJ’s findings are supported by substantial evidence, reviewing courts consider the whole record,

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