PULLIAM v. DUDEK

CourtDistrict Court, E.D. Pennsylvania
DecidedMarch 27, 2025
Docket2:23-cv-02098
StatusUnknown

This text of PULLIAM v. DUDEK (PULLIAM v. DUDEK) 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
PULLIAM v. DUDEK, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

MICHELLE P.1 : CIVIL ACTION : v. : : LELAND DUDEK, Acting : NO. 23-2098 Commissioner of Social Security2 :

MEMORANDUM AND ORDER

ELIZABETH T. HEY, U.S.M.J. March 27, 2025

Plaintiff seeks review of the Commissioner’s decision denying her application for disability insurance benefits (“DIB”) and disabled widow’s benefits (“DWB”) under Title II of the Social Security Act, and for supplemental security income (“SSI”) under Title XVI. For the reasons that follow, I conclude that the decision of the Administrative Law Judge (“ALJ”) is supported by substantial evidence. I. PROCEDURAL HISTORY Plaintiff filed her applications on March 26, 2021, tr. at 115-17, 263-64; 270-74, 279-80, alleging disability from May 26, 2020, as a result of diabetes, arthritis, asthma,

1Consistent with the practice of this court to protect the privacy interests of plaintiffs in social security cases, I will refer to Plaintiff using her first name and last initial. See Standing Order – In re: Party Identification in Social Security Cases (E.D. Pa. June 10, 2024). 2Leland Dudek became Acting Commissioner of Social Security on or about February 17, 2025, upon the resignation of Acting Commissioner Michelle King. Pursuant to Rule 25(d)(1) of the Federal Rules of Civil Procedure, Mr. Dudek should be substituted as the defendant in this case. No further action need be taken to continue this suit pursuant to section 205(g) of the Social Security Act. 42 U.S.C. § 405(g). thyroid disease, and fatty liver. Tr. at 298.3 Her applications were denied initially, id. at 70-84, 85-99, 100-14, and on reconsideration, id. at 118-26, 127-35, 136-44, and she requested an administrative hearing. Id. at 175-76. After holding a hearing on June 24,

2022, id. at 36-66, the ALJ issued an unfavorable decision on July 22, 2022. Id. at 16-30. The Appeals Council denied Plaintiff’s request for review on April 18, 2023, id. at 1-3, making the ALJ’s July 22, 2022 decision the final decision of the Commissioner. 20 C.F.R. §§ 404.981, 416.1481. Plaintiff sought review in this court on June 1, 2023, Doc. 1, and the matter is now fully briefed and ripe for review. Docs. 10-11.4

II. LEGAL STANDARD The court’s role on judicial review is to determine whether the Commissioner’s decision is supported by substantial evidence. 42 U.S.C. § 405(g); Schaudeck v. Comm’r of Soc. Sec., 181 F.3d 429, 431 (3d Cir. 1999). Therefore, the issue in this case is whether there is substantial evidence to support the Commissioner’s conclusions that

3For purposes of SSI, the earliest month for which benefits can be paid “is the month following the month [the claimant] filed the application,” if the claimant meets all the other requirements for eligibility. 20 C.F.R. § 416.335. To be entitled to DIB, Plaintiff must establish that she became disabled on or before her date last insured. Id. § 404.131(b). The Certified Earning Record indicates and the ALJ found that Plaintiff was insured through September 2021. Tr. at 17, 290. To be entitled to DWB, Plaintiff must establish that she became disabled in the month before the month in which she reached age 60 or, if earlier, the later of 7 years after the insured’s death or 7 years after the widow was last entitled to survivor’s benefits. 20 C.F.R. § 404.335(c). Plaintiff is less than 60 years of age (tr. at 43, 280) and her husband died on September 27, 2020 (id. at 279), and therefore the ALJ correctly determined that Plaintiff must establish that her disability began on or before September 30, 2027. Id. at 17. 4The parties have consented to magistrate judge jurisdiction pursuant to 28 U.S.C. § 636(c). See Standing Order – In Re: Direct Assignment of Social Security Appeals to Magistrate Judges – Extension of Pilot Program (E.D. Pa. Nov. 27, 2020); Doc. 8. Plaintiff is not disabled. Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion,” and must be “more than a mere scintilla.” Zirnsak v. Colvin, 777 F.2d 607, 610 (3d Cir. 2014) (quoting Rutherford v.

Barnhart, 399 F.3d 546, 552 (3d Cir. 2005)); see also Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (substantial evidence “means only – ‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion’”) (quoting Consol. Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). The court has plenary review of legal issues. Schaudeck, 181 F.3d at 431.

To prove disability, a claimant must demonstrate an “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment . . . which has lasted or can be expected to last for . . . not less than twelve months.” 42 U.S.C. § 423(d)(1). The Commissioner employs a five-step process, evaluating:

1. Whether the claimant is currently engaged in substantial gainful activity;

2. If not, whether the claimant has a “severe impairment” that significantly limits her physical or mental ability to perform basic work activities that has lasted or is expected to last for a continuous period of 12 months;

3. If so, whether based on the medical evidence, the impairment meets or equals the criteria of an impairment listed in the listing of impairments (“Listings”), 20 C.F.R. pt. 404, subpt. P, app. 1, which results in a presumption of disability;

4. If the impairment does not meet or equal the criteria for a listed impairment, whether, despite the severe impairment, the claimant has the residual functional capacity (“RFC”) to perform her past work; and

5. If the claimant cannot perform her past work, then the final step is to determine whether there is other work in the national economy that the claimant can perform.

See Zirnsak v. Colvin, 777 F.3d 607, 610 (3d Cir. 2014); see also 20 C.F.R. § 416.920(a)(4). Plaintiff bears the burden of proof at steps one through four, while the burden shifts to the Commissioner at the fifth step to establish that the claimant is capable of performing other jobs in the local and national economies, in light of her age, education, work experience, and RFC. See Poulos v. Comm’r of Soc. Sec., 474 F.3d 88, 92 (3d Cir. 2007). III. DISCUSSION A.

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