RENTZ v. DUDEK

CourtDistrict Court, W.D. Pennsylvania
DecidedSeptember 2, 2025
Docket2:24-cv-01293
StatusUnknown

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

Bluebook
RENTZ v. DUDEK, (W.D. Pa. 2025).

Opinion

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

BRIAN THOMAS RENTZ, ) ) Plaintiff, ) ) Civil Action No. 24-1293 v. ) ) Frank J. Bisignano, Commissioner of the ) ) Social Security Administration;1 )

Defendant.

MEMORANDUM AND ORDER OF COURT AND NOW, this 2nd day of September 2025, having considered the parties’ cross-motions for summary judgment, the Court will AFFIRM the Commissioner of the Social Security Administration’s (“Commissioner”) final decision denying Brian Thomas Rentz’s (“Rentz”) claims for disability insurance benefits and supplemental security income because the Commissioner’s findings are supported by substantial evidence. Biestek v. Berryhill, 587 U.S. 97, 102 (2019) (“On judicial review, an ALJ’s factual findings … ‘shall be conclusive’ if supported by ‘substantial evidence.’” (quoting 42 U.S.C. § 405(g))).2

1 Frank J. Bisignano was confirmed as the Commissioner of the Social Security Administration on May 6, 2025. His substitution is automatic pursuant to Fed. R. Civ. P. 25(d). See 42 U.S.C. § 405(g) (“Any action instituted in accordance with this subsection shall survive notwithstanding any change in the person occupying the office of Commissioner of Social Security or any vacancy in such office.”). 2 The Commissioner’s final decision—i.e., the decision under review in this matter—is the Administrative Law Judge’s (“ALJ”) decision. (Docket No. 4-2 at 18-25). After reviewing the record and hearing Rentz and a Vocational Expert’s (“VE”) testimony at a hearing, the ALJ concluded that Rentz was not disabled for purposes of obtaining disability insurance benefits or supplemental security income. (Id. at 25). Rentz filed a Complaint before this Court to challenge that decision (Docket No. 3), and Rentz and the Commissioner have now filed cross-motions for summary judgment by which Rentz seeks reversal and the Commissioner seeks affirmance of the underlying disability determination and denial of benefits. In his written decision, the ALJ went through the Social Security Administration’s five-step sequential evaluation process for determining disability. (Docket No. 4-2 at 19). The ALJ found that: (1) Rentz had not engaged in substantial gainful activity since August 1, 2019 (his alleged onset date); (2) Rentz has three severe impairments, major depressive disorder, generalized anxiety disorder, and history of alcohol and marijuana abuse; (3) none of Rentz’s impairments nor any combination of his impairments meets or medically equals the severity of an impairment listed in 20 CFR Part 404, Subpart P, Appendix 1; (4) Rentz has a Residual Functional Capacity (“RFC”) that encompasses the ability “to perform a full range of work at all exertional levels but with … nonexertional limitations: understanding, remembering, and carrying out detailed but uninvolved written or oral instructions; work duties and any changes must be explained, written and/or demonstrated and could be learned in 30 days or less; and work must not have strict production rates such as assembly line work or hourly time quotas; and occasional interaction with others”; and (5) considering Rentz’s age, education, and work experience, he could adjust to available work as, e.g., a laundry laborer, router, and addresser. (Id. at 18-25). These determinations at each step of the five-step evaluation led the ALJ to conclude that a “finding of ‘not disabled’ [was] … appropriate.” (Id. at 25). Before this Court, Rentz raises six intermingled arguments challenging the ALJ’s decision. In his view, reversal is warranted because: 1. The ALJ failed to “undertak[e] an evaluation of the medical evidence to determine whether the combined effects of Plaintiff’s below average intelligence … with his other mental impairments impacts [his] work ability and whether these impairments require additional restrictions” of work- related functions. (Docket No. 9 at 13-14 (citing Diaz v. Comm’r of Soc. Sec., 577 F.3d 500 (3d Cir. 2009))). 2. The ALJ erred in omitting a limitation to one- or two-step tasks from the RFC and from the hypothetical questions he posed to the VE, when such a limitation was supported by medical opinion and prior administrative medical findings evidence produced by Dr. Dante Mancini and Dr. Virginia Martin, whose findings the ALJ found to be “persuasive.” (Id. at 15-17). Rentz further argues that a one- or two-step tasks limitation is supported by his marked limitation in carrying out detailed instructions (id. at 15) and other evidence. At the very least, Rentz argues, the ALJ should have clearly explained why he did not include a one- or two-step tasks limitation. 3. The ALJ failed to account for moderate limitations in Rentz’s ability to concentrate, persist, or maintain pace, in the ALJ’s hypothetical questions to the VE and in the RFC. (Id. at 23). 4. The ALJ failed to adequately address supportability and consistency in his evaluation of the persuasiveness of certain medical opinions and prior administrative medical findings. Specifically, Rentz faults the ALJ for failing to explain his consideration of consistency for Ms. Gina Lombardi’s opinion that, among other things, Rentz has a marked limitation in social interaction. (Id. at 24). Rentz also argues that the ALJ failed to consider Dr. Tyler Reinthaler’s (Rentz’s primary care physician) treatment notes when the ALJ wrote that Dr. Reinthaler’s opinions were mere checkmark opinions that lacked a narrative explanation for significant restrictions. (Id. at 25-26). 5. The ALJ erred in failing to account for Rentz’s emotional support cat as an on-the-job limitation. (Id. at 27). Rentz further argues that the ALJ should have, at the very least, explained why he did not include a support animal among Rentz’s limitations. (Id. at 27-28). 6. The ALJ failed to do a borderline age category analysis when, at the time of the hearing, Rentz was quickly approaching fifty years of age. (Id. at 28). Several principles apply to multiple issues raised by Rentz. “[A]n ALJ must clearly set forth the reasons for his decision.” Diaz, 577 F.3d at 504. In keeping with that obligation, an ALJ must provide sufficient analysis for the Court to engage in “meaningful judicial review”; but that said, ALJs are not required to “use particular language or adhere to a particular format” in articulating the bases for their disability determinations. Id. Assessing a claimant’s RFC is the province of the ALJ. Wilkinson v. Comm’r Soc. Sec., 558 F. App’x 254, 256 (3d Cir. 2014) (citing 20 C.F.R. §§ 404.1527(d)(2), 416.927(d)(2)). The ALJ has the opportunity to see “the hearing up close,” Biestek, 587 U.S. at 108, and evaluate a claimant’s testimony alongside the other evidence of record to formulate the RFC. Therefore, it’s not appropriate for a reviewing court to “re-weigh the evidence or impose [its] own factual determinations.” Bruce v. Kijakazi, No. 3:20-CV-229, 2022 WL 973280, at *1 (W.D. Pa. Mar. 31, 2022) (quoting Chandler v. Comm’r of Soc. Sec., 667 F.3d 356, 359 (3d Cir. 2011)).

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RENTZ v. DUDEK, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rentz-v-dudek-pawd-2025.