Peterson v. Commissioner of Social Security

CourtDistrict Court, W.D. New York
DecidedSeptember 24, 2025
Docket1:24-cv-00333
StatusUnknown

This text of Peterson v. Commissioner of Social Security (Peterson 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
Peterson v. Commissioner of Social Security, (W.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

PAIGE P.,! Plaintiff, DECISION AND ORDER -vs- 24-CV-0333-MAV COMMISSIONER OF SOCIAL SECURITY, Defendant.

INTRODUCTION In April 2024, Paige P. (‘Plaintiff’) filed this action pursuant to 42 U.S.C. §§ 405(g) and 1383(c) seeking judicial review of the Commissioner of the United States Social Security Administration’s (‘Commissioner’) determination that her disability ended in December 2016, that she has not become disabled again since that date, and that she was not entitled to a continuation of her childhood Supplemental Security Income (“SSI”) benefits or SSI benefits once she became an adult. ECF No. 1. Both parties moved for judgment on the pleadings pursuant to Federal Rule of Civil Procedure 12(c). ECF No. 8 (Plaintiff); ECF No. 17 (Commissioner). For the reasons set forth below, Plaintiffs motion for judgment on the pleadings [ECF No. 8] is denied. The Commissioner’s motion [ECF No. 17] is granted. BACKGROUND The Court assumes the reader’s familiarity with the facts and procedural

1 The Court’s Standing Order issued on November 18, 2020, directs that, “in opinions filed pursuant to...42 U.S.C. § 405(g), in the United States District Court for the Western District of New York, any non-government party will be identified and referenced solely by first name and last initial.”

history in this case, and therefore addresses only those facts and issues which bear directly on the resolution of the motions presently before the Court. I. Plaintiffs Receipt of SSI Benefits as a Child Section 1382c(a)(8)(C) of Title 42 of the United States Code requires the agency to deem a child disabled for the purposes of Supplemental Security Income (“SSI”) benefits if the child: (i) “has a medically determinable physical or mental impairment, which results in marked and severe functional limitations, and 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”; and (ii) does not engage in substantial gainful activity. Plaintiff was born on October 5, 1999, making her a “school age child” at the time of her application for SSI benefits in February 2011. Administrative Record (“AR”), 129,24 ECF Nos. 5-7. On September 27, 2012, an Administrative Law Judge (“ALJ”) performed the three-step sequential analysis? required for child claimants

2 The page references from the transcripts are to the bates numbers inserted by the Commissioner, not the pagination assigned by the Court’s CM/ECF electronic filing system. 3 Whereas an adult’s claim for SSI is subject to a five-step evaluation process, claims for children are evaluated through a three-step process. Compare, e.g., 20 C.F.R. § 416.920(a)(4)G)—(v), with Id. at § 416.924(a)-(d). At step one of the three-step process for evaluating claims for children, the ALJ examines whether the child is engaged in any substantial gainful activity. 20 C.F.R. § 416.924(a)—(b). If the child is not engaged in substantial gainful activity, then the analysis moves to step two, and the ALJ considers whether the child has a medically determinable impairment or combination of impairments that is severe. 20 C.F.R. § 416.924(c). If the child has an impairment or combination of impairments that is severe, then at step three the ALJ considers whether the child has an impairment or combination of impairments that both meets the 12-month duration requirement, and meets, medically equals, or functionally equals an impairment on the listing of impairments in Appendix 1 of Subpart P of Part 404 of Title 20 of the Code of Federal Regulations (“the Listings”). 20 C.F.R. § 416.924(d). If the impairment does not meet or medically equal a listing, the agency evaluates the “functional equivalence” of the limitation or limitations in six domains of functioning: Gi) acquiring and using information; (ii) attending and completing tasks; (iii) interacting and relating with others; (iv) moving about and manipulating objects; (v) caring for oneself; and (vi) health and physical well-being. See, e.g., Roxanne H. 0/b/o A.H. v. Comm’ of Soc. Sec., No. 6:20-CV-06688 EAW, 2022 WL 4493931, at *2 (W.D.N.Y. Sept. 28, 2022) (citing Encarnacion ex rel. George v. Astrue, 568 F.3d 72, 75 (2d Cir. 2009)). A child claimant’s impairment is the “functional equivalent” of a listed impairment if that child has marked limitations in two domains of functioning, or an extreme limitation in one domain. 20

under 20 C.F.R. § 416.924, and found that Plaintiff had not engaged in any substantial gainful activity and had the following severe impairments: attention deficit, hyperactivity disorder (“ADHD”); learning disability; and pervasive personality disorder. Jd. The ALJ then found that Plaintiffs impairments caused marked limitation in three of the six functional domains identified in the Commissioner’s regulations: acquiring and using information, attending and completing tasks, and interacting and relating to others. AR at 129-132. Therefore, the ALJ found that Plaintiff's impairments functionally equaled the severity of the Listings. Id. Based on his findings of functional equivalence, the ALJ determined that Plaintiff had been under a disability since the time her application was filed in February 2011, and she was awarded SSI benefits. AR at 182. II. Cessation of Plaintiff's SSI Benefits Section 421() of Title 42 of the United States Code provides that, “[i]n any case where an individual is or has been determined to be under a disability, the case shall be reviewed by the applicable [s]tate agency or the Commissioner of Social Security (as may be appropriate), for purposes of continuing eligibility, at least once every 3 years.” 42 U.S.C. § 421(). Thus, child claimants eligible for SSI benefits are reviewed periodically to verify continued eligibility. 20 C.F.R. § 416.994a(a). This involves a three-step inquiry: (1) Has there been medical improvement in the child’s condition(s) since the

CFR. § 416.926a(d). If an impairment or combination of impairments meets, medically equals, or functionally equals the listings, and if the child meets the duration requirement, then the ALJ must find the child to be disabled. 20 C.F-R. § 416.924(d)(1).

time of the most recent favorable decision? (2) Does the child’s impairment(s) still meet or equal the severity of the listed impairment that it met or equaled before? (8) Is the child currently disabled? See 20 C.F.R. § 416.994a(b). The “most recent favorable decision” identified in the first step is referred to as the “comparison point decision” or CPD. See Roxanne H. 0/b/o A.H., 2022 WL 4493981, at *2.

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