Richmond v. O'Malley

CourtDistrict Court, D. Maryland
DecidedJuly 24, 2025
Docket1:24-cv-01825
StatusUnknown

This text of Richmond v. O'Malley (Richmond v. O'Malley) 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
Richmond v. O'Malley, (D. Md. 2025).

Opinion

CHAMBERS OF 101 WEST LOMBARD STREET CHARLES D. AUSTIN BALTIMORE, MARYLAND 21201 UNITED STATES MAGISTRATE JUDGE (410) 962-7810 MDD_CDAChambers@mdd.uscourts.gov

July 24, 2025

LETTER TO ALL COUNSEL OF RECORD

Re: Nancy R. v. Frank Bisignano, Acting Commissioner, Social Security Administration1 Civil No. 24-1825-CDA

Dear Counsel: On June 24, 2024, Plaintiff Nancy R. (“Plaintiff”) petitioned this Court to review the Social Security Administration’s (“SSA’s” or “Commissioner’s” or “Defendant’s”) final decision to deny Plaintiff’s claim for Social Security benefits. ECF 1. This case was then referred to me with the parties’ consent. See 28 U.S.C. § 636; Loc. R. 301 (D. Md. 2023). I have considered the record in this case (ECF 13) and the parties’ filings2 (ECFs 14, 15, 16). I find that no hearing is necessary. See Loc. R. 105.6 (D. Md. 2023). The Court must uphold the decision of the SSA if it is supported by substantial evidence and if the SSA 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, I will DENY Plaintiff’s motion and AFFIRM the Commissioner’s decision. This letter explains why. I. PROCEDURAL BACKGROUND Plaintiff filed a Title II application for Disability Insurance Benefits (“DIB”) on June 29, 2021, alleging a disability onset of May 5, 2021. Tr. 20, 228. Plaintiff’s claims were denied initially and on reconsideration. Tr. 81-97. On January 5, 2024, an Administrative Law Judge (“ALJ”) held a hearing. Tr. 38-63. Following the hearing, on February 16, 2024, the ALJ determined that Plaintiff was not disabled within the meaning of the Social Security Act3 during the relevant time frame. Tr. 17-32. The Appeals Council denied Plaintiff’s request for review, Tr.

1 Plaintiff filed this case against Martin O’Malley, the Commissioner of Social Security on June 24, 2024. ECF 1. Frank Bisignano became the Commissioner of Social Security on May 7, 2025. Accordingly, Commissioner Bisignano has been substituted as this case’s Defendant pursuant to Federal Rule of Civil Procedure 25(d). See Fed. R. Civ. P. 25(d). 2 Standing Order 2022-04 amended the Court’s procedures regarding SSA appeals to comply with the Supplemental Rules for Social Security Actions under 42 U.S.C. § 405(g), which became effective December 1, 2022. Under the Standing Order, parties now file dispositive “briefs” rather than “motions for summary judgment.” Here, however, Plaintiff filed a motion for summary judgment, or in the alternative, a motion to remand. See ECF 14.

3 42 U.S.C. §§ 301 et seq. July 24, 2025 Page 2

3-6, so the ALJ’s decision constitutes the final, reviewable decision of the SSA, Sims v. Apfel, 530 U.S. 103, 106–07 (2000); see also 20 C.F.R. § 422.210(a). II. THE ALJ’S DECISION The Social Security Act defines disability as the “inability 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 12 months[.]” 42 U.S.C. § 423(d)(1)(A); 20 C.F.R. §§ 404.1505(a), 416.905(a). The ALJ is required to evaluate a claimant’s disability determination using a five-step sequential evaluation process. See 20 C.F.R. §§ 404.1520, 416.920. “Under this process, an ALJ evaluates, in sequence, whether the claimant: ‘(1) worked during the alleged period of disability; (2) had a severe impairment; (3) had an impairment that met or equaled the requirements of a listed impairment; (4) could return to [their] past relevant work; and (5) if not, could perform any other work in the national economy.’” Kiser v. Saul, 821 F. App’x 211, 212 (4th Cir. 2020) (citation omitted) (quoting Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012)). At step one, the ALJ determined that Plaintiff had “not engaged in substantial gainful activity since May 5, 2021, the alleged onset date.” Tr. 22. At step two, the ALJ found that Plaintiff suffered from the severe impairments of “obesity; lumbar degenerative disc disease status post decompression; lumbar spinal stenosis; right knee osteoarthritis; chronic ankle sprain.” Id. The ALJ also determined that Plaintiff suffered from the non-severe impairments of benign essential hypertension, mixed hyperlipidemia, diabetes, obstructive sleep apnea, depression, and anxiety. Tr. 23-25. At step three, the ALJ determined that Plaintiff “does not have an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1.” Tr. 25. Despite these impairments, the ALJ determined that Plaintiff retained the residual functional capacity (“RFC”) to: perform sedentary work as defined in 20 CFR 404.1567(a) except can occasionally climb ramps or stairs and can never climb ladders, ropes or scaffolds; can occasionally balance, stoop; cannot kneel, crouch or crawl; can tolerate occasional exposure to extreme temperatures, humidity, fumes/dusts/odors/gases/poor ventilation and hazards such as dangerous moving machinery and unprotected heights.

Tr. 26. The ALJ determined that Plaintiff could perform past relevant work as an administrative assistant (DOT4 #169.167-010), as generally performed. Tr. 31. Therefore, the ALJ concluded

4 The “DOT” is the Dictionary of Occupational Titles. “The Dictionary of Occupational Titles, and its companion, Selected Characteristics of Occupations Defined in the Revised Dictionary of Occupational Titles . . . , are [SSA] resources that list occupations existing in the economy and explain some of the physical and mental requirements of those occupations. U.S. Dep’t of Labor, Dictionary of Occupational Titles (4th ed. 1991); U.S. Dep’t of Labor, Selected Characteristics of Occupations Defined in the Revised Dictionary of Occupational Titles (1993).” Pearson v. Colvin, 810 F.3d 204, 211 n.1 (4th Cir. 2015). July 24, 2025 Page 3

that Plaintiff was not disabled. Id. III. LEGAL STANDARD The scope of the Court’s review is limited to determining whether substantial evidence supports the ALJ’s factual findings and whether the decision was reached through the application of the correct legal standards. See Coffman v. Bowen, 829 F.2d 514, 517 (4th Cir. 1987). “The findings of the [ALJ] . . .

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Bluebook (online)
Richmond v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richmond-v-omalley-mdd-2025.