Marc P. v. Kijakazi

CourtDistrict Court, D. Rhode Island
DecidedJanuary 25, 2022
Docket1:21-cv-00112
StatusUnknown

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

Bluebook
Marc P. v. Kijakazi, (D.R.I. 2022).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF RHODE ISLAND

MARC P. : : v. : C.A. No. 21-00112-MSM : KILOLO KIJAKAZI, Commissioner : Social Security Administration :

REPORT AND RECOMMENDATION

Lincoln D. Almond, United States Magistrate Judge

This matter is before the Court for judicial review of a final decision of the Commissioner of the Social Security Administration (“Commissioner”) denying Supplemental Security Income benefits (“SSI”) under the Social Security Act (the “Act”), 42 U.S.C. § 405(g). Plaintiff filed his Complaint on March 8, 2021 seeking to reverse the Decision of the Commissioner. On October 31, 2021, Plaintiff filed a Motion for Reversal of the Disability Determination of the Commissioner of Social Security. (ECF No. 12). On November 30, 2021, Defendant filed a Motion to Affirm the Commissioner’s Decision. (ECF No. 13). On December 29, 2021, Plaintiff filed a Reply. (ECF No. 15). A hearing was held on January 19, 2022. This matter has been referred to me for preliminary review, findings and recommended disposition. 28 U.S.C. § 636(b)(1)(B); LR Cv 72. Based upon my review of the record, the parties’ submissions and independent research, I find that there is not substantial evidence in this record to support the Commissioner’s decision and findings that Plaintiff is not disabled within the meaning of the Act. Consequently, I recommend that Plaintiff’s Motion to Reverse (ECF No. 12) be GRANTED and that the Commissioner’s Motion to Affirm (ECF No. 13) be DENIED. I. PROCEDURAL HISTORY Plaintiff filed an application for SSI on November 30, 2018 (Tr. 311-317) alleging disability since November 13, 2018. The application was denied initially on March 26, 2019 (Tr. 178-183) and on reconsideration on May 10, 2019. (Tr. 185-190). Plaintiff requested an Administrative Hearing. On February 3, 2020, a hearing was held before Administrative Law Judge Martha Bower (the “ALJ”) at which time Plaintiff, represented by counsel, and a Vocational Expert (“VE”) appeared and testified. (Tr. 160-176). The ALJ issued an unfavorable decision to Plaintiff on February 13, 2020. (Tr. 191- 203). The Appeals Council granted Plaintiff’s request for review of the ALJ’s decision on December 2, 2020 and, on January 9, 2021, after review and consideration of additional medical evidence, the

Appeals Council adopted the ALJ’s findings and concluded that Plaintiff was not disabled within the meaning of the Social Security Act through February 13, 2020. (Tr. 1-7). A timely appeal of the January 9, 2021 Appeals Council decision was then filed with this Court. II. THE PARTIES’ POSITIONS Plaintiff argues that the Commissioner’s denial of benefits was erroneous in several respects including the failure to include undisputed limitations in the RFC finding, the failure to find his back impairment to be “severe” at Step 2, and the failure to give adequate consideration to new and material evidence arising after the period under consideration, i.e., after February 13, 2020. The Commissioner disputes Plaintiff’s claims and contends that the decision denying benefits must be affirmed because it is based on substantial evidence and free of harmful legal error. III. THE STANDARD OF REVIEW The Commissioner’s findings of fact are conclusive if supported by substantial evidence. 42 U.S.C. § 405(g). Substantial evidence is more than a scintilla – i.e., the evidence must do more than

merely create a suspicion of the existence of a fact and must include such relevant evidence as a reasonable person would accept as adequate to support the conclusion. Ortiz v. Sec’y of HHS, 955 F.2d 765, 769 (1st Cir. 1991) (per curiam); Rodriguez v. Sec’y of HHS, 647 F.2d 218, 222 (1st Cir. 1981). Where the Commissioner’s decision is supported by substantial evidence, the court must affirm, even if the court would have reached a contrary result as finder of fact. Rodriguez Pagan v. Sec’y of HHS, 819 F.2d 1, 3 (1st Cir. 1987); Barnes v. Sullivan, 932 F.2d 1356, 1358 (11th Cir. 1991). The court must view the evidence as a whole, taking into account evidence favorable as well as unfavorable to the decision. Frustaglia v. Sec’y of HHS, 829 F.2d 192, 195 (1st Cir. 1987); Parker v. Bowen, 793 F.2d 1177 (11th Cir. 1986) (court also must consider evidence detracting from evidence

on which Commissioner relied). The court must reverse the ALJ’s decision on plenary review, however, if the ALJ applies incorrect law, or if the ALJ fails to provide the court with sufficient reasoning to determine that he or she properly applied the law. Nguyen v. Chater, 172 F.3d 31, 35 (1st Cir. 1999) (per curiam); accord Cornelius v. Sullivan, 936 F.2d 1143, 1145 (11th Cir. 1991). Remand is unnecessary where all of the essential evidence was before the Appeals Council when it denied review, and the evidence establishes without any doubt that the claimant was disabled. Seavey v. Barnhart, 276 F.3d 1, 11 (1st Cir. 2001) citing, Mowery v. Heckler, 771 F.2d 966, 973 (6th Cir. 1985). The court may remand a case to the Commissioner for a rehearing under sentence four of 42 U.S.C. § 405(g); under sentence six of 42 U.S.C. § 405(g); or under both sentences. Seavey, 276 F.3d at 8. To remand under sentence four, the court must either find that the Commissioner’s decision is not supported by substantial evidence, or that the Commissioner incorrectly applied the law relevant to the disability claim. Id.; accord Brenem v. Harris, 621 F.2d 688, 690 (5th Cir. 1980) (remand

appropriate where record was insufficient to affirm, but also was insufficient for district court to find claimant disabled). Where the court cannot discern the basis for the Commissioner’s decision, a sentence-four remand may be appropriate to allow her to explain the basis for her decision. Freeman v. Barnhart, 274 F.3d 606, 609-610 (1st Cir. 2001). On remand under sentence four, the ALJ should review the case on a complete record, including any new material evidence. Diorio v. Heckler, 721 F.2d 726, 729 (11th Cir. 1983) (necessary for ALJ on remand to consider psychiatric report tendered to Appeals Council). After a sentence four remand, the court enters a final and appealable judgment immediately, and thus loses jurisdiction. Freeman, 274 F.3d at 610. In contrast, sentence six of 42 U.S.C. § 405(g) provides: The court...may at any time order additional evidence to be taken before the Commissioner of Social Security, but only upon a showing that there is new evidence which is material and that there is good cause for the failure to incorporate such evidence into the record in a prior proceeding;

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Heckler v. Campbell
461 U.S. 458 (Supreme Court, 1983)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Seavey v. Social Security
276 F.3d 1 (First Circuit, 2001)
Freeman v. Massanari
274 F.3d 606 (First Circuit, 2001)
Park Motor Mart, Inc. v. Ford Motor Company
616 F.2d 603 (First Circuit, 1980)
United States v. Emiliano Valencia-Copete
792 F.2d 4 (First Circuit, 1986)

Cite This Page — Counsel Stack

Bluebook (online)
Marc P. v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marc-p-v-kijakazi-rid-2022.