Murdough v. Commissioner of Social Security

CourtDistrict Court, M.D. Pennsylvania
DecidedApril 9, 2020
Docket3:19-cv-01408
StatusUnknown

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

Bluebook
Murdough v. Commissioner of Social Security, (M.D. Pa. 2020).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA DELICIA S. MURDOUGH,

Plaintiff, CIVIL ACTION NO. 3:19-CV-01408

v. (MEHALCHICK, M.J.)

ANDREW M. SAUL, Commissioner of Social Security,

Defendant.

MEMORANDUM OPINION Plaintiff Delicia S. Murdough brings this action under section 1631(c) of the Social Security Act, 42 U.S.C. § 1383(c) (incorporating 42 U.S.C. § 405(g) by reference), seeking judicial review of the final decision of the Commissioner of Social Security (the “Commissioner”) denying her application for supplemental security income under Title XVI of the Act. (Doc. 1). On December 11, 2019, pursuant to 28 U.S.C. § 636(c)(1), the parties consented to the undersigned’s jurisdiction to adjudicate all pretrial and trial proceedings relating to this action. (Doc. 11). For the following reasons, the Commissioner’s decision is AFFIRMED, final judgment is entered in favor of the Commissioner, and the Clerk of the Court is directed to close this case. I. BACKGROUND AND PROCEDURAL HISTORY In November 2015, Murdough filed a Title XVI application for supplemental security income, claiming disability beginning January 1, 2012, due to major depression, scoliosis, anxiety, post-traumatic stress disorder (PTSD), and bipolar disorder. (Doc. 8-6, at 6). The Social Security Administration initially denied the application in December 2015, prompting Murdough’s request for a hearing, which Administrative Law Judge (ALJ) Timothy Wing held on January 18, 2018. (Doc. 8-2, at 16). In a July 2018 written decision, the ALJ determined that Murdough is not disabled and therefore not entitled to benefits or income under Title XVI. (Doc. 8-2, at 16). The Appeals Council subsequently denied Murdough’s

request for review. (Doc. 8-2, at 2). On August 2019, Murdough commenced the instant action. (Doc. 1). The Commissioner responded in July 2019, providing the requisite transcripts from Murdough’s disability proceedings. (Doc. 7; Doc. 8). The parties then filed their respective briefs, with Murdough raising one principal bases for reversal or remand. (Doc. 10; Doc. 12). II. STANDARDS OF REVIEW To receive benefits under Title XVI of the Social Security Act, a claimant must demonstrate an “inability 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. § 1382c(a)(3)(A); 20 C.F.R. § 416.909. To satisfy this requirement, a claimant must have a severe physical or mental impairment that makes it impossible to do his or her previous work or any other substantial gainful activity that exists in significant numbers in the national economy. 42 U.S.C. § 1382c(a)(3)(B); 20 C.F.R. § 416.905(a).1 A. ADMINISTRATIVE REVIEW In evaluating whether a claimant is disabled, the “Social Security Administration,

1 A “physical or mental impairment” is defined as an impairment resulting from “anatomical, physiological, or psychological abnormalities which are demonstrable by medically acceptable clinical and laboratory diagnostic techniques.” 42 U.S.C. § 1382c(a)(3)(D). working through ALJs, decides whether a claimant is disabled by following a now familiar five-step analysis.” Hess v. Comm’r Soc. Sec., 931 F.3d 198, 200–01 (3d Cir. 2019). The “burden of proof is on the claimant at all steps except step five, where the burden is on the Commissioner of Social Security.” Hess, 931 F.3d at 201; see 20 C.F.R. § 416.912(a)(1). Thus,

if the claimant establishes an inability to do past relevant work at step four, the burden shifts to the Commissioner at step five to show that jobs exist in significant numbers in the national economy that the claimant could perform consistent with his or her residual functional capacity, age, education, and past work experience. 20 C.F.R. § 416.912(a)(1). B. JUDICIAL REVIEW The Court’s review of a determination denying an application for Title XVI benefits is limited “to considering whether the factual findings are supported by substantial evidence.” Katz v. Comm’r Soc. Sec., No. 19-1268, 2019 WL 6998150, at *1 (3d Cir. Dec. 20, 2019). Substantial evidence “does not mean a large or considerable amount of evidence, but rather such relevant evidence as a reasonable mind might accept as adequate to support a

conclusion.” Pierce v. Underwood, 487 U.S. 552, 565 (1988) (internal quotation marks omitted). The quantum of proof is less than a preponderance of the evidence but more than a mere scintilla. Richardson v. Perales, 402 U.S. 389, 401 (1971). A single piece of evidence is not substantial if the ALJ ignores countervailing evidence or fails to resolve a conflict created by such evidence. Mason v. Shalala, 994 F.2d 1058, 1064 (3d Cir. 1993). In an adequately developed factual record, substantial evidence may be “something less than the weight of the evidence, and the possibility of drawing two inconsistent conclusions from the evidence does not prevent [the ALJ’s decision] from being supported by substantial evidence.” Consolo v. Fed. Maritime Comm’n, 383 U.S. 607, 620 (1966). The question before the Court, therefore, is not whether Murdough was disabled, but whether the Commissioner’s determination that Murdough was not disabled is supported by substantial evidence and was reached based upon a correct application of the relevant law. See Arnold v. Colvin, No. 3:12-CV-02417, 2014 WL 940205, at *1 (M.D. Pa. Mar. 11,

2014) (“[I]t has been held that an ALJ’s errors of law denote a lack of substantial evidence.”); Burton v. Schweiker, 512 F. Supp. 913, 914 (W.D. Pa. 1981) (“The [Commissioner]’s determination as to the status of a claim requires the correct application of the law to the facts.”); see also Wright v. Sullivan, 900 F.2d 675, 678 (3d Cir. 1990) (noting that the scope of review on legal matters is plenary). “In determining if the Commissioner’s decision is supported by substantial evidence the court must scrutinize the record as a whole.” Leslie v. Barnhart, 304 F. Supp. 2d 623, 627 (M.D. Pa. 2003). If “the ALJ’s findings of fact . . . are supported by substantial evidence in the record,” the Court is bound by those findings. Knepp v.

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Related

Consolo v. Federal Maritime Commission
383 U.S. 607 (Supreme Court, 1966)
Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Sullivan v. Zebley
493 U.S. 521 (Supreme Court, 1990)
Warner-Lambert Company v. Breathasure, Inc.
204 F.3d 78 (Third Circuit, 2000)
Burton v. Schweiker
512 F. Supp. 913 (W.D. Pennsylvania, 1981)
Leslie v. Barnhart
304 F. Supp. 2d 623 (M.D. Pennsylvania, 2003)
Barbara Pennington v. Commissioner Social Security
683 F. App'x 168 (Third Circuit, 2017)
Russell Hess, III v. Commissioner Social Security
931 F.3d 198 (Third Circuit, 2019)

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Murdough v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/murdough-v-commissioner-of-social-security-pamd-2020.