RIVERA v. O'MALLEY

CourtDistrict Court, M.D. North Carolina
DecidedJanuary 6, 2025
Docket1:24-cv-00205
StatusUnknown

This text of RIVERA v. O'MALLEY (RIVERA v. O'MALLEY) is published on Counsel Stack Legal Research, covering District Court, M.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
RIVERA v. O'MALLEY, (M.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF NORTH CAROLINA VICTOR R., ) ) Plaintiff, ) ) v. ) 1:24CV205 ) CAROLYN W. COLVIN, ) Acting Commissioner of Social ) Security, ) ) Defendant.1 ) MEMORANDUM OPINION AND RECOMMENDATION OF UNITED STATES MAGISTRATE JUDGE Plaintiff, Victor R., brought this action pursuant to the Social Security Act (the “Act”) to obtain judicial review of a final decision of Defendant, the Acting Commissioner of Social Security (the “Commissioner”), denying Plaintiff’s claim for Disability Insurance Benefits (“DIB”). (Docket Entry 1.) Defendant has filed the certified administrative record (Docket Entry 3 (cited herein as “Tr. __”)), and both parties have submitted dispositive briefs in accordance with Rule 5 of the Supplemental Rules for Social Security Actions under 42 U.S.C. § 405(g) (Docket Entry 7 (Plaintiff’s Brief); Docket Entry 8 (Commissioner’s Brief)). For the reasons that follow, the Court should remand this matter for further administrative proceedings. 1 Carolyn W. Colvin became the Acting Commissioner of Social Security on November 30, 2024. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Carolyn W. Colvin should substitute for Martin J. O’Malley as the defendant in this suit. No further action need be taken to continue this suit by reason of the last sentence of Section 205(g) of the Social Security Act, 42 U.S.C. § 405(g). I. PROCEDURAL HISTORY Plaintiff applied for DIB on April 11, 2020 (Tr. 302-11), alleging disability since March 13, 2020 (see Tr. 302, 305). Upon denial of that application initially (Tr. 98-120, 144-52) and on reconsideration (Tr. 121-31, 154-58), Plaintiff requested a hearing de novo before an Administrative Law Judge (“ALJ”) (Tr. 159-60). Plaintiff, his attorney, and a vocational expert (“VE”) attended the hearing. (Tr. 63-83.) The ALJ subsequently ruled that Plaintiff did not qualify as disabled under the Act. (See Tr. 134.)2 The Appeals Council granted Plaintiff’s request for review (Tr. 132-38; see also Tr. 59-61, 444-45 (request for review)), and remanded the case for the ALJ to consider new and material “evidence consist[ing] of a Medical Source Statement from Sherry A. Smith, Ed.D., LCSW/Cape Fear Behavioral Health Center, LLC (Dated: October 23, 2021; 6 pages), which indicate[d] that the claimant . . . [wa]s ‘seriously limited,’ ‘unable to meet competitive standards,’ or ha[d] ‘no useful ability to function in’

most areas of ‘Mental Abilities and Aptitudes Needed to do Unskilled Work’” (Tr. 134 (referencing Tr. 1674-79) (quoting Tr. 1675)). The ALJ held a second hearing, attended by Plaintiff, his attorney, and a different VE. (Tr. 40-57.) The ALJ subsequently issued a decision finding Plaintiff not disabled. (Tr. 14-39.) 2 That decision does not appear in the record. 2 The Appeals Council thereafter denied Plaintiff’s request for review (Tr. 1-6, 299-301), thereby making the ALJ’s ruling the Commissioner’s final decision for purposes of judicial review. In rendering that disability determination, the ALJ made the following findings later adopted by the Commissioner: 1. [Plaintiff] meets the insured status requirements of the . . . Act through December 31, 2025. 2. [Plaintiff] has not engaged in substantial gainful activity since March 13, 2020, the alleged onset date. . . . 3. [Plaintiff] has the following severe impairments: degenerative disc disease with chronic lower back pain; obesity; vertigo due to inner ear disorder; tinnitus with hearing loss; ulnar entrapment, status-post surgery; chronic migraines; post-traumatic stress disorder (PTSD); and adjustment disorder with depressed mood. . . . 4. [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. . . . 5. . . . [Plaintiff] has the residual functional capacity to perform light work . . . . with the following provisions: frequent climbing of ramps and stairs, balancing, kneeling, crouching, and crawling; occasional climbing of step ladders up to four feet in vertical height but none higher; no climbing of ropes or scaffolds; avoid concentrated exposure to workplace hazards (as defined in the Selected Characteristics of Occupations (SCO)) and to no[i]se levels greater than moderate (as defined in the SCO) due to a history of migraines; ability to understand, remember, and carry out instructions for simple, routine tasks not at production pace (i.e. not subject to strict time deadlines and/or quota requirements); ability to maintain concentration, 3 persistence, and pace for two-hour segments for completion of simple, routine tasks (assuming normal 15- minute morning and afternoon breaks and a 30-minute lunch break); frequent interaction with supervisors; occasional interaction with coworkers; no interaction with the public; ability to adapt to workplace changes involving simple, work-related decisions. . . . 6. [Plaintiff] is unable to perform any past relevant work. . . . 10. Considering [Plaintiff]’s age, education, work experience, and residual functional capacity, there are jobs that exist in significant numbers in the national economy that [he] can perform. . . . 11. [Plaintiff] has not been under a disability, as defined in the . . . Act, from March 13, 2020, through the date of th[e ALJ’s] decision. (Tr. 19-31 (bold font and internal parenthetical citations omitted).) II. DISCUSSION Federal law “authorizes judicial review of the Social Security Commissioner’s denial of social security benefits.” Hines v. Barnhart, 453 F.3d 559, 561 (4th Cir. 2006). However, “the scope of [the Court’s] review of [such a] decision . . . is extremely limited.” Frady v. Harris, 646 F.2d 143, 144 (4th Cir. 1981). Even given those limitations, the Court should remand this case for further administrative proceedings.

4 A. Standard of Review “[C]ourts are not to try [a Social Security] case de novo.” Oppenheim v. Finch, 495 F.2d 396, 397 (4th Cir. 1974). Instead, the Court “must uphold the factual findings of the ALJ if they are supported by substantial evidence and were reached through application of the correct legal standard.” Hines, 453 F.3d at 561 (internal brackets and quotation marks omitted). “Substantial evidence means ‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Hunter v. Sullivan, 993 F.2d 31, 34 (4th Cir. 1992) (quoting Richardson v. Perales, 402 U.S. 389, 401 (1971)). “It consists of more than a mere scintilla of evidence but may be somewhat less than a preponderance.” Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001) (brackets and internal quotation marks omitted).

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Bluebook (online)
RIVERA v. O'MALLEY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rivera-v-omalley-ncmd-2025.