Nelson v. Dudek

CourtDistrict Court, D. Minnesota
DecidedFebruary 28, 2025
Docket0:24-cv-00039
StatusUnknown

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

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Nelson v. Dudek, (mnd 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA

KIMBERLY K. N., Case No. 24-CV-00039 (JFD)

Plaintiff,

v. ORDER ON MOTION FOR SUMMARY JUDGMENT LELAND DUDEK, Acting Commissioner of Social Security,

Defendant.

This matter is before the Court on the Complaint of Plaintiff Kimberly K. N. (Dkt. No. 1) seeking judicial review, pursuant to 42 U.S.C. § 405(g), of a final decision by the Commissioner of Social Security, who denied her applications for Supplemental Security Income (SSI) and disability insurance benefits (DIB). (Pl. Mot. Summ. J. 1, Dkt. No. 11.) Plaintiff states she is living with cervical degenerative disc disease, right shoulder tendinitis, left hip arthritis, and asthma. (Soc. Sec. Admin. R. (hereinafter “R.”) 15–24.)1 Plaintiff challenges the Commissioner’s final decision, saying it was “an abuse of discretion” and that while the Administrative Law Judge (“ALJ”) found that she could not adequately perform her past employment as generally performed, he erred in finding that she could perform the job as she actually performed it. (Pl.’s Mem. in Supp. of Summ. J. 1, Dkt. No. 12 (“Pl. Br.”).) Plaintiff claims that this decision constituted “reversible error.”

1 The consecutively paginated Social Security administrative record is filed at docket number 6. The Court cites to that pagination rather than to the docket number and page assigned by the Court’s CM/ECF system. (Id.) The case is currently before the Court on the parties’ cross-motions for summary judgment. (Dkt. Nos. 11, 14). The undersigned finds that the ALJ’s decision is supported

by substantial evidence, denies Plaintiff’s Motion for Summary Judgment, and grants the Commissioner’s Motion for Summary Judgment. I. BACKGROUND A. Process for Applying for Disability Benefits People with disabilities can qualify for financial support from the Social Security Administration (SSA) through one or both of its assistance programs: the Disability Insurance (DIB) Program under Title II of the Social Security Act and the Supplemental Security Income (SSI) Program under Title XVI of the Act. Smith v. Berryhill, 587 U.S.

471, 475 (2019) (citing Bowen v. Galbreath, 485 U.S. 74, 75 (1988)). DIB is an insurance program that provides support to those who have worked and had sufficient social security taxes withheld from their pay to qualify for coverage if they become disabled. Id. 42 U.S.C. § 423(a) (guaranteeing benefits for insured disabled people). SSI is a public assistance program that provides support to people with disabilities, whether or not they have paid

social security taxes, who demonstrate financial need. Smith, 587 U.S. at 475; 42 U.S.C. § 1381a (guaranteeing support to eligible “aged, blind, or disabled” people); 20 C.F.R. § 416.110 (explaining program’s purpose). Plaintiff sought benefits under both programs. The Social Security Act defines disability as the “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. § 423(d)(1)(A). It further defines a physical or mental impairment as one “that results from anatomical, physiological, or psychological abnormalities which are demonstrable by medically

acceptable clinical and laboratory diagnostic techniques.” 42 U.S.C. § 423(d)(3). To receive benefits from either DIB or SSI, claimants submit applications to the SSA, which grants or denies them according to its own regulations. 20 C.F.R. § 404.900 (outlining DIB administrative process under Title II); 20 C.F.R. § 416.1400 (outlining SSI administrative process under Title XVI). SSA officials grant or deny an application at what is called the “initial determination.” 20 C.F.R.§ 404.900(a)(1); 20 C.F.R.§ 416.1400(a)(1).

If a claimant is unsuccessful at their initial determination and wants the decision reviewed, they must timely file a request for reconsideration. 20 C.F.R.§§ 404.900(a)(2), 404.909, 416.1400(a)(2), 416.1409. If the claimant’s application is denied at the reconsideration level and the claimant wants the reconsideration reviewed, they must timely ask for a hearing before an administrative law judge (“ALJ”). 20 C.F.R.§§ 404.900(a)(3), 404.933,

416.1400(a)(3), 416.1433. The ALJ determines whether the person is disabled using the five-step analysis described in the social security regulations. See 20 C.F.R. §§ 404.1520, 416.920. At each step, the ALJ decides whether the person is disabled under the criteria of that step. If the answer is “yes,” the analysis goes no further, and the person is deemed disabled. If the

answer is “no,” the ALJ continues to the next step. For the first four steps, the claimant bears the burden of proof. Bowen v. Yuckert, 482 U.S. 137, 146 n. 5 (1987). Steps one through four ask: (1) whether the claimant has engaged in substantial gainful activity since the alleged onset of disability (if they have been working for pay, they cannot be deemed disabled), (2) whether the claimant is suffering from a severe medical impairment, (3) whether claimant’s impairment meets or equals the severity of one or more of the

impairments listed in the Listing of Impairments (20 C.F.R. Part 404, Subpart P, App. 1), and (4) whether the claimant has the Residual Functional Capacity (RFC) to perform their past relevant work (PRW). 20 C.F.R. § 404.1520. If the claimant successfully meets their burden of proof for steps one through four, the Commissioner bears the burden at step five to establish that the claimant can perform other work that exists in significant numbers in the national economy. See 20 C.F.R. §§ 404.1505(a), 404.1512(f), 404.1520(a)(4)(v).

If the claimant is dissatisfied with the ALJ’s decision, they can request that a panel of the Social Security Appeals Council review the ALJ’s decision. 20 C.F.R. §§ 404.900(a)(4), 404.968, 416.1400(a)(4), 416.1468.

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