ONLEY v. OMALLEY

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 26, 2025
Docket5:24-cv-00427
StatusUnknown

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

Bluebook
ONLEY v. OMALLEY, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF PENNSYLVANIA

MEGAN O.,1 : Plaintiff, : CIVIL ACTION v. : No. 24-427 : LELAND DUDEK, : Acting Commissioner of : Social Security, : Defendant. :

MEMORANDUM

JOSÉ RAÚL ARTEAGA March 26, 2025 United States Magistrate Judge2

The Commissioner of Social Security, through an Administrative Law Judge (“ALJ”), determined that Plaintiff was not disabled and denied Plaintiff’s claim for Supplemental Security Income (“SSI”) benefits under Title XVI of the Social Security Act, 42 U.S.C. §§ 1381-1383.3 Plaintiff seeks review of the decision, challenging the ALJ’s (1) consideration of the agency’s examining expert; (2) residual functional capacity (“RFC”) finding; and (3) consideration of Plaintiff’s “need to lie down during the day.”

1 The caption follows this Court’s standing order in referring to Megan O. solely by Plaintiff’s first name and last initial. See Standing Order, In re: Party Identification in Social Security Cases (E.D. Pa. June 10, 2024), https://www.paed.uscourts.gov/sites/paed/files/documents/locrules/standord/SO_ pty-id-ss.pdf (last visited Feb. 25, 2025).

2 The parties have consented to the jurisdiction of a United States Magistrate Judge to conduct all proceedings, including the entry of a final judgment, pursuant to 28 U.S.C. § 636(c). (ECF 9.)

3 42 U.S.C. § 1383(c)(3) renders the judicial review provisions of 42 U.S.C. § 405(g) fully applicable to claims for SSI. (ECF 16.) The Commissioner contends that Plaintiff’s arguments “undermine the substantial evidence” that exists to support the ALJ’s decision. (ECF 17.)

After careful consideration of the entire record, Plaintiff’s request for review is denied and the Commissioner’s decision is affirmed for the following reasons. I. BACKGROUND Plaintiff protectively filed a claim for SSI on April 5, 2021, at age 19, two years after graduating from high school. (Tr. 645-46.) Plaintiff alleged disability beginning on that date because of autism, anxiety, and depression. (Tr. 136.) At the time of filing, Plaintiff

had neither found employment nor returned to school. (Tr. 645-46.) Plaintiff’s claim was denied initially and on reconsideration. (Tr. 52-75.) Plaintiff and a vocational expert (“VE”) testified at a December 22, 2022 hearing. (Tr. 37-51.) After the hearing, the ALJ determined Plaintiff was not entitled to SSI. (Tr. 17-28.) At step one, the ALJ found that Plaintiff had not performed work after the benefits

application date. (Tr. 19.) At steps two and three, the ALJ found that Plaintiff had severe autism spectrum disorder level 1; depression; gender dysphoria; schizoid personality disorder; bilateral patellofemoral arthritis; hypermobility of joints; and obesity, but Plaintiff’s impairments did not meet or equal one of the Commissioner’s listed impairments. (Tr. 19-21.) Before turning to steps four and five, the ALJ determined that

Plaintiff retained the residual functional capacity (“RFC”) to perform: “light work as defined in 20 C.F.R. § 416.967(b) except frequent climbing of ramps, stairs, balance, stoop, kneel, crouch, and crawl, occasional climbing of ladders, ropes, scaffolds, and” that Plaintiff was “limited to work in a low stress environment, defined as only occasional changes in the work setting and no interaction with the public.” (Tr. 21.) The ALJ found that Plaintiff’s medically determinable impairments could reasonably be expected to

cause the Plaintiff’s alleged symptoms, but that “statements concerning the intensity, persistence and limiting effects of these symptoms [were] not entirely consistent with the medical evidence and other evidence in the record . . . .” (Tr. 22.) More specifically, the ALJ considered Plaintiff’s history of bilateral knee pain, but found that imaging studies were “overall unremarkable and overall stable” and that the record supported “normal physical examination findings.” (Tr. 27.) In addition, despite Plaintiff’s history of obesity,

Plaintiff’s weight was “overall stable” and there was “evidence of at least some success with weight loss.” (Id.) The ALJ also noted Plaintiff’s “history of mental health impairments,” but found the record supported “overall stable mental status examination findings, as well as improvement in terms of [Plaintiff’s] self esteem following . . . surgery and overall improvement in mood.” (Id.) Although Plaintiff “reported a general feeling”

of not fitting in when in social situations, Plaintiff had friends, was able to use public transportation, attend group sessions, attend yoga, and go to the library.” (Id.) At step four, the ALJ determined that Plaintiff had no past relevant work. (Id.) At step five, the ALJ relied on the VE’s testimony to conclude that Plaintiff was capable of performing jobs including small products assembler, mail sorter, and cleaner: all light,

unskilled occupations. (Tr. 28, 49-49.) As a result, the ALJ determined that Plaintiff was not disabled because Plaintiff was “capable of making a successful adjustment to other work that exists in significant numbers in the national economy.” (Tr. 28.) Plaintiff filed a request for review of the ALJ’s determination, which the Appeals Council declined. (Tr. 1-3.) Plaintiff commenced this action on January 30, 2024. (ECF 1.)

II. LEGAL STANDARDS The limited question before the Court is not whether Plaintiff was disabled. Rather, the Court must determine whether substantial evidence supports the Commissioner’s finding that Plaintiff was not and whether the Commissioner, through the ALJ, correctly applied the relevant law. 42 U.S.C. § 405(g). An ALJ follows a five-step sequential-evaluation process to determine whether a claimant is disabled, considering

in sequence whether: (1) the claimant is engaged in substantial gainful activity; (2) he or she has a severe impairment; (3) the claimant’s impairment meets or equals a listed impairment4; (4) the claimant is able to do his or her past relevant work; and (5) he or she is able to do any other work, considering his or her age, education, work experience, and residual functional capacity (“RFC”). 20 C.F.R. § 404.1520(a)(4)(i)–(v). A claimant “bears

the burden of proof at steps one through four” of the sequential-evaluation process. Smith v. Comm’r of Soc. Sec., 631 F.3d 632, 634 (3d Cir. 2010). At step five, “the Commissioner bears the burden of establishing the existence of jobs in the national economy that an individual with the claimant’s impairments is capable of performing.” Zirnsak v. Colvin, 777 F.3d 607, 616 (3d Cir. 2014).

Relevant to Plaintiff’s claims here, the RFC is what a claimant “‘is still able to do despite the limitations caused by . . . [the claimant’s] impairment(s).’” Burnett v. Comm’r

4 The listings of impairments are found at 20 C.F.R. pt. 404, subpt. P, app. 1. of Soc. Sec. Admin., 220 F.3d 112, 121 (3d Cir.

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ONLEY v. OMALLEY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/onley-v-omalley-paed-2025.