Plis v. Commissioner of Social Security

CourtDistrict Court, N.D. New York
DecidedAugust 27, 2025
Docket5:24-cv-01008
StatusUnknown

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

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Plis v. Commissioner of Social Security, (N.D.N.Y. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF NEW YORK ________________________________________

JOSEPH P.,

Plaintiff,

v. 5:24-CV-1008 (DNH/ML) COMMISSIONER OF SOCIAL SECURITY,

Defendant. ________________________________________

APPEARANCES: OF COUNSEL:

OLINSKY LAW GROUP HOWARD OLINSKY, ESQ. Counsel for Plaintiff DANIEL J. BRADY, ESQ. 250 South Clinton Street, Suite 210 Syracuse, New York 13202

SOCIAL SECURITY ADMINISTRATION KRISTINA D. COHN, ESQ. Counsel for Defendant 6401 Security Boulevard Baltimore, Maryland 21235

MIROSLAV LOVRIC, United States Magistrate Judge

REPORT and RECOMMENDATION

Plaintiff Joseph P. (“Plaintiff”) brings this action pursuant to 42 U.S.C. § 405(g) seeking judicial review of a final decision of the Commissioner of Social Security (“Defendant”) denying his application for Social Security Disability Insurance benefits. (Dkt. No. 1.) This matter was referred to me for Report and Recommendation by the Honorable David N. Hurd, Senior United States District Judge, pursuant to 28 U.S.C. § 636(b) and Local Rule 72.3(d). (Dkt. Nos. 4, 5.) This case has proceeded in accordance with General Order 18. Currently before this Court are Plaintiff’s motion for judgment on the pleadings and Defendant’s motion for judgment on the pleadings. (Dkt. Nos. 10, 12, 13.) For the reasons set forth below, this Court recommends that the District Court grant Defendant’s motion for judgment on the pleadings and affirm the Commissioner’s decision.

I. PROCEDURAL HISTORY On August 10, 2021, Plaintiff protectively filed an application for Title II Social Security Disability benefits, alleging disability beginning on March 5, 2019. (Administrative Transcript (“T.”) 224-32.) His application was initially denied on October 28, 2021, and the denial was affirmed upon reconsideration on June 30, 2022. (T. 110-16, 124-35.) Plaintiff’s request for a hearing was granted. (T. 140-193.) On November 30, 2023, Plaintiff testified by telephone before Administrative Law Judge (“ALJ”) Jennifer Smith, who also heard the testimony of vocational expert (“VE”) David Salewsky. (T. 42-76.) Plaintiff was represented at the hearing by qualified representative Kimberly MacDougall. (T. 44-45.) The ALJ issued an unfavorable decision on December 22, 2023. (T. 17-34.) The Appeals Council denied Plaintiff’s request for

review on June 27, 2024. (T. 1-6.) Plaintiff commenced this proceeding on August 15, 2024, to challenge the Commissioner’s denial of disability benefits. (Dkt. No. 1.) II. GENERALLY APPLICABLE LAW A. Scope of Review In reviewing a final decision of the Commissioner, a court must determine whether the correct legal standards were applied and whether substantial evidence supports the decision. Featherly v. Astrue, 793 F. Supp. 2d 627, 630 (W.D.N.Y. 2011) (citations omitted); Rosado v. Sullivan, 805 F. Supp. 147, 153 (S.D.N.Y. 1992) (citing Johnson v. Bowen, 817 F.2d 983, 985 (2d Cir. 1987)). A reviewing court may not affirm the ALJ’s decision if it reasonably doubts whether the proper legal standards were applied, even if the decision appears to be supported by substantial evidence. Johnson, 817 F.2d at 986. A court’s factual review of the Commissioner’s final decision is limited to the

determination of whether there is substantial evidence in the record to support the decision. 42 U.S.C. § 405(g) (2015); Rivera v. Sullivan, 923 F.2d 964, 967 (2d Cir. 1991). To facilitate the court’s review, an ALJ must set forth the crucial factors justifying his or her findings with sufficient specificity to allow a court to determine whether substantial evidence supports the decision. Roat v. Barnhart, 717 F. Supp. 2d 241, 248 (N.D.N.Y. 2010); see also Ferraris v. Heckler, 728 F.2d 582, 587 (2d Cir. 1984). “Substantial evidence has been defined as ‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Williams ex rel. Williams v. Bowen, 859 F.2d 255, 258 (2d Cir. 1988) (citations omitted). It must be “more than a mere scintilla” of evidence scattered throughout the administrative record. Featherly, 793 F. Supp. 2d at 630; Richardson v. Perales, 402 U.S. 389, 401 (1971) (quoting

Consol. Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). “To determine on appeal whether an ALJ’s findings are supported by substantial evidence, a reviewing court considers the whole record, examining the evidence from both sides, because an analysis of the substantiality of the evidence must also include that which detracts from its weight.” Williams, 859 F.2d at 258 (citations omitted). Where substantial evidence supports the ALJ’s findings they must be sustained “even where substantial evidence may support the plaintiff’s positions and despite that the court’s independent analysis of the evidence may differ from the [ALJ’s].” Rosado, 805 F. Supp. at 153. In other words, a reviewing court cannot substitute its interpretation of the administrative record for that of the Commissioner if the record contains substantial support for the ALJ’s decision. Rutherford v. Schweiker, 685 F.2d 60, 62 (2d Cir. 1982). B. Standard for Benefits1 To be considered disabled, a plaintiff-claimant seeking benefits must establish that he or she is “unable 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 twelve months.” 42 U.S.C. § 1382c(a)(3)(A). In addition, the plaintiff-claimant’s physical or mental impairment or impairments [must be] of such severity that he is not only unable to do his previous work but cannot, considering his age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy, regardless of whether such work exists in the immediate area in which he lives, or whether a specific job vacancy exists for him, or whether he would be hired if he applied for work. Id. § 1382c(a)(3)(B). Acting pursuant to its statutory rulemaking authority (42 U.S.C. § 405(a)), the Social Security Administration (“SSA”) promulgated regulations establishing a five-step sequential evaluation process to determine disability. 20 C.F.R. § 416.920(a)(4) (2015).

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Barnhart v. Thomas
540 U.S. 20 (Supreme Court, 2003)
Ferraris v. Heckler
728 F.2d 582 (Second Circuit, 1984)
Matta v. Astrue
508 F. App'x 53 (Second Circuit, 2013)
Zabala v. Astrue
595 F.3d 402 (Second Circuit, 2010)
Featherly v. Astrue
793 F. Supp. 2d 627 (W.D. New York, 2011)
Roat v. Barnhart
717 F. Supp. 2d 241 (N.D. New York, 2010)
Pardee v. Astrue
631 F. Supp. 2d 200 (N.D. New York, 2009)
Rosado v. Sullivan
805 F. Supp. 147 (S.D. New York, 1992)
McIntyre v. Colvin
758 F.3d 146 (Second Circuit, 2014)

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