Patel v. Commissioner, Social Security

CourtDistrict Court, D. Maryland
DecidedDecember 20, 2021
Docket8:19-cv-01434
StatusUnknown

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

Bluebook
Patel v. Commissioner, Social Security, (D. Md. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF MARYLAND Southern Division

YOGESHCHANDRA K. P., * * Plaintiff, * * Civil No. TMD 19-1434 v. * * * KILOLO KIJAKAZI, * Acting Commissioner of Social Security, * * Defendant.1 * ************

MEMORANDUM OPINION

On May 16, 2019, Plaintiff pro se Yogeshchandra P. petitioned this Court to review the final decision of the Social Security Administration (“Defendant,” the “Commissioner,” the “SSA,” or the “Agency”) determining the amount of overpayment for which he is liable. ECF No. 1. Upon the parties’ consent, this case was transferred to a United States Magistrate Judge for final disposition and entry of judgment. The case subsequently was reassigned to the undersigned. Before the Court are Plaintiff’s Motion for Summary Judgment (ECF No. 25), Defendant’s Motion for Summary Judgment (ECF No. 31), and Plaintiff’s Reply Memorandum and alternative motion for remand (ECF No. 33).2 No hearing is necessary. L.R. 105.6. The Court must uphold the decision of the SSA if it is supported by substantial evidence and if the

1 On July 9, 2021, Kilolo Kijakazi became the Acting Commissioner of Social Security. She is, therefore, substituted as Defendant in this matter. See 42 U.S.C. § 405(g); Fed. R. Civ. P. 25(d).

2 The Fourth Circuit has noted that, “in social security cases, we often use summary judgment as a procedural means to place the district court in position to fulfill its appellate function, not as a device to avoid nontriable issues under usual Federal Rule of Civil Procedure 56 standards.” Walls v. Barnhart, 296 F.3d 287, 289 n.2 (4th Cir. 2002). For example, “the denial of summary judgment accompanied by a remand to the Commissioner results in a judgment under sentence four of 42 U.S.C. § 405(g), which is immediately appealable.” Id. Agency employed proper legal standards. See 42 U.S.C. §§ 405(g), 1383(c)(3); Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996). Under that standard, the Court grants Defendant’s Motion for Summary Judgment and affirms the SSA’s final decision under the fourth sentence of 42 U.S.C. § 405(g). A. Standard of Review

The Court reviews an ALJ’s decision to determine whether the ALJ applied the correct legal standards and whether the factual findings are supported by substantial evidence. See Craig, 76 F.3d at 589. The Court’s review is deferential, as “[t]he findings of the Commissioner of Social Security as to any fact, if supported by substantial evidence, shall be conclusive.” 42 U.S.C. § 405(g). Under this standard, substantial evidence is less than a preponderance but is enough that a reasonable mind would find it adequate to support the Commissioner’s conclusion. See Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012); see also Biestek v. Berryhill, 587 U.S. ___, 139 S. Ct. 1148, 1154 (2019). In evaluating the evidence in an appeal of a denial of benefits, the court does “not conduct a de novo review of the evidence,” Smith v. Schweiker, 795

F.2d 343, 345 (4th Cir. 1986), or undertake to reweigh conflicting evidence, make credibility determinations, or substitute its judgment for that of the Commissioner. Hancock, 667 F.3d at 472. Rather, “[t]he duty to resolve conflicts in the evidence rests with the ALJ, not with a reviewing court.” Smith v. Chater, 99 F.3d 635, 638 (4th Cir. 1996). When conflicting evidence allows reasonable minds to differ as to whether a claimant is disabled, the responsibility for that decision falls on the ALJ. Johnson v. Barnhart, 434 F.3d 650, 653 (4th Cir. 2005) (per curiam). B. Discussion Plaintiff was found disabled as of October 2008 and began receiving disability insurance benefits on April 1, 2009. R. at 18, 19. On June 27, 2013, the SSA issued a notice informing Plaintiff that he was overpaid Title II benefits in the amount of $109,091.00 from April 1, 2009, to June 1, 2013, because of work activity. R. at 18. On July 28, 2013, the SSA reversed that final decision to a denial because of business reports showing that Plaintiff was working at substantial, gainful activity (“SGA”) levels at the time he was found disabled and continued to work. R. at 18. Plaintiff filed a request for reconsideration, which the SSA denied. R. at 18. At

Plaintiff’s request, an Administrative Law Judge (“ALJ”) held a hearing on May 1, 2018, in Washington, D.C., where Plaintiff, represented by an attorney, testified. R. at 18. After the hearing, Plaintiff submitted a request for waiver of overpayment on May 11, 2018. R. at 18. On May 17, 2018, the ALJ issued a decision (R. at 15-26) finding that Plaintiff was overpaid benefits in the amount of $109,091.00 during the period from April 1, 2009, to June 1, 2013, and that he was at fault in causing the overpayment. The ALJ found that Plaintiff “received information from Social Security explaining [SGA] limits and how they affect disability benefits.” R. at 23. “The reporting responsibilities and [SGA] language were clearly printed on his initial application, award letter, and subsequent notices.” R. at 23. “Further,

[Plaintiff] does not allege an inability to understand these reporting responsibilities. Despite receipt of information describing his reporting duties, [Plaintiff] did not report his work to the Social Security Administration.” R. at 23. “As such, he continued to receive benefits when he should have known that he was not entitled to them, based on his previous receipt of the pertinent information.” R. at 23. The ALJ found that Plaintiff “was at fault because he failed to notify the Social Security Administration of his continued work, and accepted payment of benefits that he either knew or could have been expected to know was incorrect.” R. at 23. The ALJ thus found that Plaintiff was liable for the overpayment. R. at 23-24. The Appeals Council denied Plaintiff’s request for review on March 21, 2019. R. at 4-8. An overpayment is defined as “the difference between the amount paid to the beneficiary and the amount of the payment to which the beneficiary was actually entitled.” 20 C.F.R. § 404.504. When an overpayment occurs, the SSA will adjust any benefit payments due to an overpaid claimant, or recover the funds by, for example, requiring the claimant to refund the overpayment. See 42 U.S.C. § 404(a)(1)(A). The SSA bears the burden of proving the fact and

amount of overpayment. McCarthy v. Apfel,

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Patel v. Commissioner, Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/patel-v-commissioner-social-security-mdd-2021.