LEMP v. DUDEK

CourtDistrict Court, W.D. Pennsylvania
DecidedMay 6, 2025
Docket2:24-cv-00575
StatusUnknown

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

Bluebook
LEMP v. DUDEK, (W.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA

MICHAEL LEMP ) ) Plaintiff, ) ) v. ) Civil Action No. 24-575 ) Judge Nora Barry Fischer LELAND DUDEK, ) Commissioner of Social Security, ) ) Defendant. ) MEMORANDUM OPINION I. INTRODUCTION Michael Lemp (“Plaintiff”) brings this action pursuant to 42 U.S.C. § 405(g), seeking review of the final determination of the Commissioner of Social Security (“Defendant” or “Commissioner”) denying his May 16, 2023 application for disability insurance benefits (“DIB”) under Title II of the Social Security Act, 42 U.S.C. §§ 401-403 (the “Act”). This matter comes before the Court on cross motions for summary judgment. (Docket Nos. 6 (Plaintiff) and 9 (Defendant)). As more fully set forth in Section V below, prior to taking the unusual step of dismissing this claim at step two – a preliminary step which serves as a “screening device” intended to “dispose of groundless claims” - the Administrative Law Judge (the “ALJ”) was required to find on substantial evidence that Plaintiff’s “medically determinable impairments” did not meet that step 2 gatekeeping criteria - i.e., that Plaintiff failed to meet his “[un-]exacting” burden to evidence a “more than minimal limitation on his ability to work.” Magwood v. Comm’r of Soc. Sec., 417 F. App’x 130, 132 (3d Cir. 2008); McCrea v. Comm’r of Soc. Sec., 370 F. 3d 357, 360 (3d Cir. 2004) (citing S.S.R. 85-28, 1985 WL 56856 at *3). And in making this determination, the ALJ was required to construe reasonable doubts/ambiguities regarding the sufficiency of

claimant’s evidence in the light most favorable to him. McCrea, supra, (holding that “[a]ny doubt as to whether this showing has been made is to be resolved in favor of the applicant” and this step should be “rarely utilized” to deny benefits); Newell v. Comm'r of Soc. Sec., 347 F.3d 541, 547 (3d Cir. 2003)).1 On deferential review, the Court is compelled to find that the record simply does not reasonably support a step 2 denial of this claim as groundless under the above standard. Rather, here, the ALJ was presented evidence of Plaintiff’s history of mental health treatment through the Veterans Administration (the “VA”), including a six-day hospitalization shortly prior to his alleged August 1, 2018 disability onset date, followed by three months in a VA residential program, and another hospitalization – this one for 11 days – in June, 2019,

shortly prior to his “date last insured” (“DLI”) of June 30, 2019. Plaintiff’s VA records also include the notes and opinion(s) of his VA treating psychologists, including those of Dr. Kisslinger (August-October 2018 Domiciliary program); Dr. Graham (June 13-24, 2019 admission); and Dr. Bulgarelli (2020 to 2023). On the basis of the 10-year-long VA records before him, Plaintiff’s last treating psychologist of record, Dr. Bulgarelli,(a) identified Plaintiff’s

1 See also S.S.R. 85-28 (“Great care should be exercised in applying the not severe impairment concept. If an adjudicator is unable to clearly determine the effect of an impairment or combination of impairments on the individual’s ability to do basic work activities, the sequential evaluation process should not end with [step 2].”). Cf. Docket No. 7 at 4 (“SSA policy describes a step 2 denial as an option that is only available in the presence of unambiguous evidence [of a no more than de minimis effect on] ability to work.”).

The Court notes that the aforesaid clarifications of the intent of and special considerations at step 2 are recognized in neither the Hearing Decision rendered on Plaintiff’s claim nor Defendant’s Brief in Support of its Motion for Summary Judgment. (Docket No. 4-2 at 11-23; Docket No. 10). “primary conditions and symptoms” (for the length of Plaintiff’s treatment at the VA) as “recurrent and chronic major depression disorder with anxious distress2 – moderate to severe” which “markedly impairs his ability to function”, and (b) documented the continuation of those

conditions for more than three (3) years following Plaintiff’s June 30, 2019 DLI. As discussed in Section V, infra, Dr. Bulgarelli, who identified multiple specific continuous/chronic mental health impairments to Plaintiff’s ability to work, was largely disregarded by the ALJ because he concededly treated Plaintiff only after 2019 and she found his views inconsistent with “the full longitudinal record”. The ALJ also largely dismissed Plaintiff’s hearing testimony regarding his worsening mental health disabilities from 2014 (and prior) through 2019 as lacking objective record support; and while credibility determinations are within the ALJ’s province,3 Plaintiff’s testimony of daily living, social interactions and mental/emotional health status is not entirely without other support. Under the “de minimis” standard applicable at stage two, and the resolution of any doubt

to be made in Plaintiff’s favor, the Court finds that the ALJ erred in dismissing this claim without further evaluation. See discussion at Section V(A), infra; McCrea, 370 F. 3d at 360; Newell, 347 F.3d at 547. See also Fisher v. Comm’r of Soc. Sec., Civil Action No. 19-672-ANB, 2020 U.S. Dist. LEXIS 149999, at *8 (W.D. Pa. Aug. 19, 2020) (finding where record contains some evidence that claimant had significant limitations of ability to do basic work activities, analysis of weighing and evaluation of that evidence is not appropriate at the “clearinghouse” level of step 2, but rather

2 In support, Dr. Bulgarelli further endorsed the “medical documentation” of “panic attacks” and “disproportionate fear or anxiety about at least two different situations”, such as being outside one’s home. (Docket No. 4-10 at 8-9).

3 See, e.g., Van Horn v. Schweiker, 717 F.2d 871, 873 (3d Cir. 1983). “at the later steps of the sequential process”) (citing Magwood v. Comm’r of Soc. Sec., 417 Fed. Appx. 130, 132-33 (3d Cir. 2008)).

Plaintiff’s Motion for Summary Judgment [6] is accordingly granted in the form of reversal and remand of the final determination of the Commissioner, while Defendant’s Motion for Summary Judgment [9] is denied.4 II. PROCEDURAL HISTORY Plaintiff applied for DIB on May 16, 2023. Plaintiff’s alleged disability onset date was initially June 30, 2013, but was later amended (on November 9, 2023, prior to his hearing) to August 1, 2018,5 and his DLI was June 30, 2019. The Social Security Administration (the

“SSA”) denied his application initially (June 21, 2023) and upon reconsideration (July 17, 2023). After the SSA informed Plaintiff that he did not qualify for benefits, Plaintiff requested, appeared and testified at an approximately 45 minute long telephonic hearing held on November 16, 2023, before the designated ALJ, Joanna Papazekos. Plaintiff was represented at said hearing by his then-counsel, Melanie Davis. Louis Szollosy, an impartial vocational expert, also appeared at the hearing and testified briefly. On January 19, 2024, the ALJ issued a hearing decision finding that Plaintiff had not been under a disability from the alleged onset date through Plaintiff's June 30, 2019 DLI (the “ALJ Decision”). Specifically, at step two, the ALJ conducted a two-part analysis pursuant to 20 CFR

Pt. 404, Subpt. P, App. 1, in which she first found that, through his DLI, Plaintiff had “medically

4 This Court may, under 42 U.S.C. § 405

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LEMP v. DUDEK, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lemp-v-dudek-pawd-2025.