Meyer v. Commissioner of Social Security

CourtDistrict Court, W.D. New York
DecidedApril 25, 2025
Docket1:24-cv-00182
StatusUnknown

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

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

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

JACQUELINE M.,1

Plaintiff, Case # 24-CV-182-FPG

v. DECISION AND ORDER

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

INTRODUCTION Plaintiff Jacqueline M. brings this action pursuant to the Social Security Act seeking review of the final decision of the Commissioner of Social Security that denied her application for Supplemental Security Income (“SSI”) under Title XVI of the Act. ECF No. 1. The Court has jurisdiction over this action under 42 U.S.C. §§ 405(g), 1383(c)(3). Plaintiff moved for judgment on the pleadings pursuant to Federal Rule of Civil Procedure 12(c), requesting that the case be remanded either for the calculation of benefits or for further administrative proceedings. ECF No. 13. The Commissioner confesses error and moves to remand for further proceedings. ECF No. 20. For the reasons that follow, the Commissioner’s motion is GRANTED, Plaintiff’s motion is GRANTED IN PART, and this matter is remanded for further administrative proceedings. BACKGROUND In February 2016, Plaintiff applied for SSI with the Social Security Administration (“the SSA”). Tr.2 144. She alleged disability since February 2015 due to a number of physical and mental impairments. Id. In June 2018, Administrative Law Judge William M. Weir issued a

1 Under this District’s Standing Order, any non-government party must be referenced solely by first name and last initial.

2 “Tr.” refers to the administrative record in this matter. ECF Nos. 5-8. decision finding that Plaintiff was not disabled. Tr. 180-90. In February 2019, the Appeals Council remanded the matter back to Judge Weir, concluding that Judge Weir had failed to consider recent treatment records. Tr. 195-98. In January 2020, Judge Weir issued a new decision finding that Plaintiff is not disabled. Tr. 22-39. In October 2020, the Appeals Council denied

Plaintiff’s request for review. Tr. 1-4. On appeal, the SSA stipulated to a remand for further proceedings. Tr. 2325-27. The Appeals Council directed that Plaintiff’s substance abuse and psychotherapy records be more fully evaluated. Tr. 2330-33. In November 2023, Administrative Law Judge Stephan Bell (the “ALJ”) issued a decision finding that Plaintiff is not disabled. Tr. 2242-53. This action seeks review of the Commissioner’s final decision. ECF No. 1. LEGAL STANDARD I. District Court Review “In reviewing a final decision of the SSA, this Court is limited to determining whether the SSA’s conclusions were supported by substantial evidence in the record and were based on a correct legal standard.” Talavera v. Astrue, 697 F.3d 145, 151 (2d Cir. 2012) (quotation marks

omitted); see also 42 U.S.C. § 405(g). The Act holds that a decision by the Commissioner is “conclusive” if it is supported by substantial evidence. 42 U.S.C. § 405(g). “Substantial evidence means more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Moran v. Astrue, 569 F.3d 108, 112 (2d Cir. 2009) (quotation marks omitted). It is not the Court’s function to “determine de novo whether [the claimant] is disabled.” Schaal v. Apfel, 134 F.3d 496, 501 (2d Cir. 1998) (quotation marks omitted). II. Disability Determination An ALJ must follow a five-step sequential evaluation to determine whether a claimant is disabled within the meaning of the Act. See Bowen v. City of New York, 476 U.S. 467, 470-71 (1986). At Step One, the ALJ must determine whether the claimant is engaged in substantial

gainful work activity. See 20 C.F.R. § 416.920(b). If so, the claimant is not disabled. If not, the ALJ proceeds to Step Two and determines whether the claimant has an impairment, or combination of impairments, that is “severe” within the meaning of the Act, meaning that it imposes significant restrictions on the claimant’s ability to perform basic work activities. Id. § 416.920(c). If the claimant does not have a severe impairment or combination of impairments, the analysis concludes with a finding of “not disabled.” If the claimant does, the ALJ continues to Step Three. At Step Three, the ALJ examines whether a claimant’s impairment meets or medically equals the criteria of a listed impairment in Appendix 1 of Subpart P of Regulation No. 4 (the “Listings”). Id. § 416.920(d). If the impairment meets or medically equals the criteria of a Listing and meets the durational requirement, id. § 416.909, the claimant is disabled. If not, the ALJ

determines the claimant’s residual functional capacity (“RFC”), which is the ability to perform physical or mental work activities on a sustained basis, notwithstanding limitations for the collective impairments. See id. § 416.920(e)-(f). The ALJ then proceeds to Step Four and determines whether the claimant’s RFC permits him or her to perform the requirements of his or her past relevant work. Id. § 416.920(f). If the claimant can perform such requirements, then he or she is not disabled. Id. If he or she cannot, the analysis proceeds to the fifth and final step, wherein the burden shifts to the Commissioner to show that the claimant is not disabled. Id. § 416.920(g). To do so, the Commissioner must present evidence to demonstrate that the claimant “retains a residual functional capacity to perform alternative substantial gainful work which exists in the national economy” in light of his or her age, education, and work experience. See Rosa v. Callahan, 168 F.3d 72, 77 (2d Cir. 1999) (quotation marks omitted); see also 20 C.F.R. § 416.960(c). DISCUSSION

I. The ALJ’s Decision The ALJ analyzed Plaintiff’s claim for benefits under the process described above. At step one, the ALJ found that Plaintiff had not engaged in substantial gainful activity since the application date. Tr. 2244. At step two, the ALJ found that Plaintiff has severe impairments of lumbar spine sciatica, complex regional pain syndrome, bipolar disorder, post-traumatic stress disorder, and alcohol and substance abuse disorder. Id. At step three, the ALJ found that Plaintiff’s impairments do not meet or medically equal any Listings impairment. Tr. 2245. Next, the ALJ determined that Plaintiff retains the RFC to perform a reduced range of sedentary work. Tr. 2247. At step four, the ALJ found that Plaintiff has no past relevant work. Tr. 2251. At step five, the ALJ found that there were jobs that existed in significant numbers in

the national economy that Plaintiff could perform. Tr. 2251-52. The ALJ therefore found that Plaintiff was not disabled. Tr. 2252. II.

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Related

Bowen v. City of New York
476 U.S. 467 (Supreme Court, 1986)
Talavera v. Comm’r of Social Security
697 F.3d 145 (Second Circuit, 2012)
Moran v. Astrue
569 F.3d 108 (Second Circuit, 2009)
Michaels v. Colvin
621 F. App'x 35 (Second Circuit, 2015)
Mariani v. Colvin
567 F. App'x 8 (Second Circuit, 2014)

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Meyer v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/meyer-v-commissioner-of-social-security-nywd-2025.