Rubio v. O'Malley

CourtDistrict Court, S.D. Florida
DecidedSeptember 30, 2025
Docket1:24-cv-23589
StatusUnknown

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

Bluebook
Rubio v. O'Malley, (S.D. Fla. 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 24-CV-23589-ELFENBEIN

MARISABEL RUBIO,

Plaintiff,

v.

FRANK BISIGNANO,1 COMMISSIONER OF SOCIAL SECURITY,

Defendant. ________________________________________/

ORDER THIS CAUSE is before the Court on Plaintiff Marisabel Rubio’s (“Plaintiff”) Amended Motion for Summary Judgment, ECF No. [18]. Defendant Frank Bisignano, Acting Commissioner of Social Security Administration (“Defendant”), filed a Motion for Summary Judgment and Response to Plaintiff’s Motion for Summary Judgment with Supporting Memorandum of Law (the “Response”), ECF No. [19].2 The Parties have not opted out of the undersigned’s jurisdiction and, therefore, have consented to it. See ECF No. [5] at 2 (“If no party objects to Magistrate Judge jurisdiction within this timeframe, then this case will proceed in full before the undersigned Magistrate Judge for all purposes, including entering any dispositive order and final judgment.”). Having reviewed the Parties’ filings, the record, and the relevant law, Plaintiff’s Motion for Summary Judgment, ECF No. [18], is DENIED, Defendant’s Motion for Summary Judgment,

1 Frank Bisignano became the Acting Commissioner of Social Security on May 7, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Frank Bisignano should be substituted as the Defendant in this suit.

2 The filing at ECF No. [19] is identical to the one at ECF No. [20]. ECF No. [19], is GRANTED, and the Administrative Law Judge’s Decision (“ALJ’s Decision”) is AFFIRMED. I. BACKGROUND On April 23, 2021, Plaintiff applied for disability insurance benefits (“DIB”) under the

Social Security Act (the “Act”), 42 U.S.C. § 401 et seq., alleging disability based on (1) “mental health problems,” (2) “digestive problems,” and (3) “headaches.” See ECF No. [7] at 70.3 The Social Security Administration (“SSA”) initially denied Plaintiff’s disability application, and again upon reconsideration. See id. at 69-90. Thereafter, Plaintiff requested a hearing, which an Administrative Law Judge (“ALJ”) held on April 14, 2023. See id. at 39-89, 110. The ALJ issued an unfavorable decision on June 27, 2023, finding Plaintiff not disabled. See id. at 23-33. The Appeals Council denied Plaintiff’s request for review on June 22, 2024, thus making the ALJ’s decision final. See id. at 5-10. II. LEGAL STANDARDS A. Judicial Review of Claims under the Act

A court’s review of an ALJ’s decision is limited to assessing whether there is substantial evidence in the record to support the ALJ’s findings and whether the ALJ applied the correct legal standards in reaching his or her determination. See Biestek v. Berryhill, 587 U.S. 97, 104 (2019). Moreover, the Court will affirm an ALJ’s decision so long as substantial evidence supports it. See Dyer v. Barnhart, 395 F.3d 1206, 1210 (11th Cir. 2005) (“If the Commissioner’s decision is supported by substantial evidence, this Court must affirm, even if the proof preponderates against it.” (quotation marks omitted)).

3 The references to page numbers from the record refer to the CM-ECF page numbers. The standard for substantial evidence requires more than a mere scintilla and necessitates relevant evidence that a reasonable person would accept as sufficient to uphold a conclusion. See Hale v. Bowen, 831 F.2d 1007, 1011 (11th Cir. 1987) (finding that substantial evidence is “more than a scintilla, but less than a preponderance”). Courts “may not decide the facts anew, reweigh

the evidence, or substitute [their] judgment for that of the [ALJ].” Winschel v. Comm’r of Soc. Sec., 631 F.3d 1176, 1178 (11th Cir. 2011) (citation omitted). Even if the evidence leans against the ALJ’s decision, the court must uphold it if substantial evidence supports it. See See Dyer v. Barnhart, 395 F.3d 1206, 1210 (11th Cir. 2005) (“If the Commissioner’s decision is supported by substantial evidence, this Court must affirm, even if the proof preponderates against it.” (citation omitted)); Bloodsworth v. Heckler, 703 F.2d 1233, 1239 (11th Cir. 1983) (citing 42 U.S.C. § 405(g)). B. Regulatory Framework for Weighing Medical Opinions Social Security regulations require the ALJ to consider and evaluate all evidence, including medical opinions. 20 C.F.R. § 404.1513(a). Medical opinions are statements “from a medical

source about what [the claimant] can still do despite [her] impairment(s) and whether [the claimant] ha[s] one or more impairment-related limitations or restrictions” in her ability to “perform physical demands of work activities”; “perform mental demands of work activities”; “perform other demands of work, such as seeing, hearing, or using other senses”; and “adapt to environmental conditions, such as temperature extremes or fumes.” Id. § 404.1513(a)(2). Relevant here, “mental demands of work activities” means “understanding; remembering; maintaining concentration, persistence, or pace; carrying out instructions; or responding appropriately to supervision, co-workers, or work pressures in a work setting.” Id. § 404.1513(a)(2)(ii). When evaluating “medical opinions and prior administrative medical findings,” the ALJ “will not defer or give any specific evidentiary weight, including controlling weight, to any medical opinion(s) or prior administrative medical finding(s), including those from” a claimant’s “medical sources,” id. § 404.1520c(a), but she “will articulate in” her “determination or decision

how persuasive” she finds “all of the medical opinions and all of the prior administrative medical findings in” the claimant’s “case record,” id. § 404.1520c(b). In doing so, the ALJ primarily considers four factors: (1) supportability; (2) consistency; (3) the medical source’s relationship with the claimant4; and (4) specialization. Id. § 404.1520c(c)(1)–(4); see also Harner v. Soc. Sec. Admin., Comm’r, 38 F.4th 892, 897 (11th Cir. 2022) (Section 404.1520c(c) “provides several factors for determining what weight to give a claimant’s proffered medical opinions. Those factors include the supportability of the medical opinion, its consistency with other record evidence, the physician’s relationship with the claimant, [and] the physician’s specialty.”). The ALJ also considers “other factors that tend to support or contradict a medical opinion or prior administrative medical finding,” including “evidence showing a medical source has familiarity with the other

evidence in the claim or an understanding of” the SSA’s “disability program’s policies and evidentiary requirements.” 20 C.F.R. § 404.1520c(c)(5); see also Harner, 38 F.4th at 897 (noting the ALJ considers “other relevant information, such as the physician’s familiarity with the other record evidence and with making a claim for disability”).

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Rubio v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rubio-v-omalley-flsd-2025.