Rooney v. Kijakazi

CourtDistrict Court, M.D. Pennsylvania
DecidedJanuary 21, 2025
Docket4:23-cv-00685
StatusUnknown

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

Bluebook
Rooney v. Kijakazi, (M.D. Pa. 2025).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA KELLY R.,1 ) CIVIL ACTION NO. 4:23-CV-00685 Plaintiff ) ) v. ) ) (ARBUCKLE, M.J.) FRANK BISIGNANO,2 ) Defendant ) MEMORANDUM OPINION I. INTRODUCTION Kelly R. is an adult who lives in the Middle District of Pennsylvania. She seeks judicial review of the final decision of the Commissioner of Social Security (“Commissioner”) denying her application for supplemental security income under Title XVI of the Social Security Act. Jurisdiction is conferred on this Court pursuant to 42 U.S.C. §1383(c)(3)(incorporating 42 U.S.C. §405(g) by reference). This matter is before me upon consent of the parties pursuant to 28 U.S.C. § 636(c) and Rule 73 of the Federal Rules of Civil Procedure. (Doc. 7). After reviewing the parties’ briefs, the Commissioner’s final decision, and the relevant portions of the certified administrative transcript, we find the Commissioner's final

1 We adopt the recommendation of the Committee on Court Administration and Case Management of the Judicial Conference of the United States that federal courts refer to social security plaintiffs by their first name and last initial. 2 Frank Bisignano became the Acting Commissioner of Social Security on January 20, 2025. He is automatically substituted as a party pursuant to Fed. R. Civ. P. 25(d); see also 42 U.S.C. § 405(g). decision is supported by substantial evidence. Accordingly, the Commissioner’s final decision will be AFFIRMED.

II. BACKGROUND AND PROCEDURAL HISTORY On November 30, 2018, Plaintiff protectively filed an application for supplemental security income under Title XVI of the Social Security Act. (Admin. Tr. 111; Doc. 9-3, p. 37). In this application, Plaintiff alleged she became disabled

on November 30, 2018, when she was forty-three years old, due to the following conditions: herniated disk in the neck and back; nerve damage; migraines; depression; PTSD; and acid reflux. (Admin. Tr. 307; Doc. 9-6, p. 6). Plaintiff alleges

that the combination of these conditions affects her ability to lift, squat, bend, stand, walk, sit, kneel, climb stairs, see, and complete tasks. (Admin. Tr. 321; Doc. 9-6, p. 20). Plaintiff attended school through the ninth grade. (Admin. Tr. 308; Doc. 7). Before the onset of her impairments, Plaintiff worked as a bus monitor at a school

and a cashier in retail. (Admin. Tr. 308; Doc. 9-6, p. 7). On March 22, 2019, Plaintiff’s application was denied at the initial level of administrative review. (Admin. Tr. 138; Doc. 9-4, p. 5). On March 26, 2019, Plaintiff

requested an administrative hearing. (Admin. Tr. 143; Doc. 9-4, p. 10). On November 9, 2020, Plaintiff and her counsel participated in a telephone hearing before Administrative Law Judge Daniel Balutis. (Admin. Tr. 33; Doc. 9-2, p. 34). On January 8, 2021, the ALJ issued a decision denying Plaintiff’s application for benefits. (Admin. Tr. 108; Doc. 9-3, p. 34). On February 4, 2021, Plaintiff requested that the Appeals Council of the Office of Disability Adjudication and

Review (“Appeals Council”) review the ALJ’s decision. (Admin. Tr. 218; Doc. 9-4, p. 85). On September 14, 2021, the Appeals Council vacated the ALJ’s hearing

decision and remanded Plaintiff’s case for a new hearing. (Admin. Tr. 130; Doc. 9- 3, p. 56). On January 25, 2022, Plaintiff and her counsel participated in a telephone hearing before the ALJ. (Admin. Tr. 67; Doc. 9-2, p. 68). On February 14, 2022, the ALJ issued a decision denying Plaintiff’s application for benefits. (Admin. Tr. 12;

Doc. 9-2, p. 13). On February 14, 2022, Plaintiff requested that the Appeals Council review the ALJ’s decision. (Admin. Tr. 218; Doc. 9-4, p. 85). The Appeals Council denied review on February 24, 2023. (Admin. Tr. 1; Doc. 9-2, p. 2).

On April 25, 2023, Plaintiff filed a complaint in federal court requesting judicial review of the Commissioner’s final decision. (Doc. 1). In the complaint, Plaintiff alleges that the ALJ’s decision denying her application is not supported by substantial evidence and contains errors of law. (Doc. 1, ¶¶ 18-19). As relief,

Plaintiff requests that the court award benefits, or remand this matter to the Social Security Administration for further consideration. (Doc. 1). The Commissioner answered the complaint. (Doc. 8). In the answer, the

Commissioner maintains that the decision denying Plaintiff’s application was made in accordance with the law and is supported by substantial evidence. (Doc. 8, ¶ 8). Along with his answer, the Commissioner filed a certified transcript of the

administrative record. (Doc. 9). Plaintiff’s Brief (Doc. 10), the Commissioner’s Brief (Doc. 14), and Plaintiff’s reply have been filed. (Doc. 15). This matter is now ready to decide.

III. LEGAL STANDARDS Before looking at the merits of this case, it is helpful to restate the legal principles governing Social Security Appeals, including the standard for substantial evidence review, and the guidelines for the ALJ’s application of the five-step

sequential evaluation process. We will also discuss the framework an ALJ uses to evaluate medical opinions and prior administrative medical findings. A. SUBSTANTIAL EVIDENCE REVIEW – THE ROLE OF THIS COURT A district court’s review of ALJ decisions in social security cases is limited to

the question of whether the findings of the final decision-maker are supported by substantial evidence in the record.3 Substantial evidence “does not mean a large or considerable amount of evidence, but rather such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”4 Substantial evidence is

3 See 42 U.S.C. § 405(g); Johnson v. Comm’r of Soc. Sec., 529 F.3d 198, 200 (3d Cir. 2008); Ficca v. Astrue, 901 F. Supp. 2d 533, 536 (M.D. Pa. 2012). 4 Pierce v. Underwood, 487 U.S. 552, 565 (1988). less than a preponderance of the evidence but more than a mere scintilla.5 A single piece of evidence is not substantial if the ALJ ignores countervailing evidence or

fails to resolve a conflict in the record.6 In an adequately developed factual record, substantial evidence may be “something less than the weight of the evidence, and the possibility of drawing two inconsistent conclusions from the evidence does not prevent [the ALJ’s decision] from being supported by substantial evidence.”7 When

determining if the Commissioner’s decision is supported by substantial evidence under sentence four of 42 U.S.C. § 405(g), the court may consider any evidence that was in the record that was made before the ALJ.8

The Supreme Court has underscored the limited scope of district court review in this field, noting that: The phrase “substantial evidence” is a “term of art” used throughout administrative law to describe how courts are to review agency factfinding. T-Mobile South, LLC v. Roswell, 574 U.S. ––––, ––––, 135 S.Ct.

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Rooney v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rooney-v-kijakazi-pamd-2025.