Lofton v. O'Malley

CourtDistrict Court, D. Connecticut
DecidedMarch 13, 2025
Docket3:24-cv-00111
StatusUnknown

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

Bluebook
Lofton v. O'Malley, (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT

SHENEE L., : : Plaintiff, : : v. : No. 3:24-cv-111 (SDV) : MARTIN O’MALLEY, : : Defendant. :

RULING ON PLAINTIFF’S MOTION TO REVERSE DECISION OF COMMISSIONER AND DEFENDANT’S MOTION TO AFFIRM

Plaintiff appeals from the administrative decision of the Commissioner of the Social Security Administration denying her application for supplemental security income. 1 For the reasons below, plaintiff’s Motion to Reverse, ECF 18, is DENIED and the Commissioner’s Motion to Affirm, ECF 19, is GRANTED. A. LEGAL STANDARDS 1. Disability and eligibility A claimant is disabled under the Social Security Act if he or she is “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 12 months.” 42 U.S.C. § 423(d)(1)(A). Title XVI of the Act provides for supplemental security income benefits to claimants who are indigent and disabled, without reference to prior work. See 42 U.S.C. § 1381 et seq.

1 Plaintiff also applied for disability insurance benefits, R. 359, but conceded in her prehearing brief that the application was effectively for SSI only because her date last insured was in December 2006. R. 454. 2. Commissioner’s five-step review The Commissioner of Social Security is authorized to make findings of fact and decide disability applications, see 42 U.S.C. § 1383(c)(1)(A), in accordance with the five-step sequential evaluation process provided in 20 C.F.R. § 416.920. (1) First, the Commissioner determines whether the claimant is currently engaged in substantial gainful activity. (2) If not,

the Commissioner determines whether the claimant has a medically determinable impairment or combination of impairments that are “severe,” meaning that it “significantly limits” the claimant’s physical or mental ability to do basic work activities. (3) If the claimant has a severe impairment or combination of impairments, the Commissioner evaluates whether, based solely on the medical evidence, the claimant has an impairment that “meets or equals” an impairment listed in Appendix 1, Subpart P, No. 4 of the regulations (the “Listings”) and that either is expected to result in death or has lasted or will last for at least 12 months. 2 If so, the claimant is disabled. (4) If not, the Commissioner determines whether, despite the severe impairment, the claimant has the residual functional capacity (“RFC”) to perform his or her past work. 3 (5) If

not, the Commissioner determines whether there is other work in the national economy which the claimant can perform considering his or her RFC, age, education, and work experience. See 20 C.F.R. § 416.920. The claimant bears the burden of proof on the first four steps, and the Commissioner bears the burden of proof on the final step. McIntyre v. Colvin, 758 F.3d 146, 150 (2d Cir. 2014).

2 See 20 C.F.R. § 416.909 (durational requirement).

3 Residual functional capacity is the most a claimant can do in a work setting despite his or her limitations. 20 C.F.R. § 416.945. The Commissioner’s authority to make these findings and decisions is delegated to an administrative law judge (“ALJ”). See 20 C.F.R. § 416.1429. A claimant may request review of an ALJ’s decision by the Appeals Council. See 20 C.F.R. § 416.1467. If the Appeals Council declines review or affirms the ALJ’s decision, the claimant may appeal to the United States District Court. 42 U.S.C. §§ 405(g), 1383(c)(3).

3. Court’s review on appeal A district court reviewing the Commissioner’s final decision is performing an appellate function, see Zambrana v. Califano, 651 F.2d 842, 844 (2d Cir. 1981), and has the power to affirm, modify, or reverse the Commissioner’s decision based on its review of the briefs and the administrative record. See 42 U.S.C. § 405(g). “A district court may set aside the Commissioner’s determination that a claimant is not disabled only if the factual findings are not supported by substantial evidence or if the decision is based on legal error.” Shaw v. Chater, 221 F.3d 126, 131 (2d Cir. 2000) (internal quotation marks omitted). B. BACKGROUND

The Court assumes familiarity with the medical record and hearing testimony but provides the following summary to contextualize its decision. 1. Procedural History In September 2020, plaintiff filed a Title XVI application for supplemental security income alleging a disability onset date of May 6, 2020. R. 361. The claims were denied at the initial review and reconsideration levels, and plaintiff requested a hearing in 2021. R. 134, 161, 169-70, 223. On November 2, 2022, ALJ Eskunder Boyd conducted a telephonic hearing at which plaintiff, her adult daughter, and a vocational expert testified. R. 38-82. On December 16, 2022, the ALJ issued a written decision denying plaintiff’s claim. R. 11-24. Plaintiff’s request for review was denied by the Appeals Council, R. 1-6, and plaintiff filed this action on June 25, 2024. 2. Personal history Plaintiff was 46 years old on the date of her September 2020 application. Her earnings record is remarkable for relatively high earnings through 2001, followed by zero earnings

between 2002 and 2007, limited earnings between 2008 and 2012, and no earnings thereafter. R. 385. Plaintiff testified that her health deteriorated after her divorce in 2006, when she was diagnosed with lupus. R. 50. She relies heavily on her adult daughters for support with financial and domestic tasks. R. 45, 67. Plaintiff’s daughter also testified at the hearing that plaintiff cycles from stable mental health to unstable every two to three weeks, and these episodes start with pain and swelling that leads to depression, sadness and frustration, ultimately requiring hospital treatment. R. 72. 3. Overview of physical conditions Regarding physical impairments, plaintiff’s brief focuses on Systemic Lupus Erythematosus (“SLE” or “lupus”)4 and Sjögren’s disease. 5 The record includes notes of eight

4 “Systemic lupus erythematosus (lupus) is a chronic (long-lasting) autoimmune disease[.] Lupus occurs when the immune system, which normally helps protect the body from infection and disease, attacks its own tissues.

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Related

Genier v. Astrue
606 F.3d 46 (Second Circuit, 2010)
Josephine L. Cage v. Commissioner of Social Security
692 F.3d 118 (Second Circuit, 2012)
Schillo v. Kijakazi
31 F.4th 64 (Second Circuit, 2022)
McIntyre v. Colvin
758 F.3d 146 (Second Circuit, 2014)
Smith v. Commissioner of Social Security
572 F. App'x 363 (Sixth Circuit, 2014)
Zambrana v. Califano
651 F.2d 842 (Second Circuit, 1981)

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Bluebook (online)
Lofton v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lofton-v-omalley-ctd-2025.