Saltos v. O'Malley

CourtDistrict Court, M.D. Pennsylvania
DecidedAugust 13, 2024
Docket3:24-cv-00006
StatusUnknown

This text of Saltos v. O'Malley (Saltos v. O'Malley) 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
Saltos v. O'Malley, (M.D. Pa. 2024).

Opinion

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

THOMAS NICHOLAS SALTOS, : Civil No. 3:24-CV-006 : Plaintiff, : : v. : (Magistrate Judge Carlson) : MARTIN O’MALLEY, : Commissioner of Social Security : : Defendant. :

MEMORANDUM OPINION

I. Introduction This Social Security appeal illustrates a cardinal principle in the art of advocacy: astute issue selection. Through the careful identification of legal issues, counsel can greatly advance the cause of their clients. Conversely, unwise issue selection may, on occasion, snatch defeat from the jaws of success. That is almost what happened here. On appeal, the focus of Saltos’ argument was his contention that the Administrative Law Judge (ALJ) erred at Step 3 of the sequential analysis which governs disability claims. Given the very exacting nature of the plaintiff’s burden at Step 3 to show disability per se, this argument fails. However, embedded within this sweeping but unpersuasive claim was a narrower argument with much greater persuasive power. Specifically, Saltos contends that the

1 ALJ completely failed to analyze, address, or acknowledge two treating source medical opinions, both of which supported Saltos’ disability claim.

On this narrow ground, which we find was barely preserved for appeal, plaintiff in this case, Saltos, is correct. Therefore, we will remand this case for further consideration of this particular issue.

II. Statement of Facts and of the Case

With respect to this medical opinion issue, the administrative record of Saltos’ disability application reveals the following essential facts: On August 28, 2020, Saltos, who was born in 1984, filed an application for child’s insurance benefits, alleging disability beginning September 1, 1995. (Tr. 14). In this application for disability benefits, Saltos alleged that he was disabled due to an array of emotional impairments, including depression, anxiety with social phobia, obsessive

compulsive disorder, and body dysmorphic disorder. (Tr. 16). With respect to this constellation of emotional impairments, the administrative record reveals at least five medical opinions, however, only three of these opinions are acknowledged by the ALJ in his decision.

First, on October 28, 2020, a state agency expert, Dr. John Gavazzi, opined that Saltos suffered from no medically determinable impairments. (Tr. 67-69). Five months later, on March 12, 2021, a second state agency expert, Dr. Frederic Small

2 issued a reconsideration decision which reached slightly different conclusions, Specifically, Dr. Small found that Saltos’ emotional impairments were medically

determinable but concluded that their severity could not be readily identified. (Tr. 71-79). In the decision denying this application for benefits, the ALJ characterized both of these opinions as unpersuasive. (Tr. 22).

In addition, the ALJ acknowledged some medical opinions provided by a former treating source, Dr. Uma Devi. (Tr. 21). Dr. Devi had opined in 2002 that Saltos’ emotional impairments limited his ability to work before large groups and adjust to sudden stresses or changes in his work environment. (Tr. 308). Later in

2021, Dr. Devi explained that Saltos was disabled due to chronic mental health issues, and as an “ideal” candidate for disability benefits. (Tr, 756-57). In the decision denying Saltos’ application for benefits, the ALJ described Dr. Devi’s

opinions as “partially persuasive.” (Tr. 20). The record, however, reveals two other medical opinions from treatment sources, both of whom found that Saltos was totally disabled due to his emotional impairments. On August 10, 2022, Dr. Johar Shah and Dr. Angelo Fordimondo, both

of whom were treating Saltos, completed disability assessment forms which described Saltos as totally disabled due to the anxiety he experienced as a result of his body dysmorphia. (Tr. 766-777). Neither of these treating source opinions was

3 analyzed, addressed, or even acknowledged by the ALJ in the decision denying Saltos’ application for benefits.

Fourteen days after these two treating sources opined that Saltos was disabled, on August 24, 2022, a disability hearing was conducted by an ALJ in this case, at which Saltos, his mother, and a vocational expert testified. (Tr. 29-65). Following

the hearing, on October 4, 2022, the ALJ issued a decision denying Saltos’ application for benefits. (Tr. 11-24).1 In that decision, the ALJ first concluded that Saltos had not attained the age of 22 at the time of the alleged onset of his disability in 1995 and had not engaged in substantial gainful activity since that time. (Tr. 16).

At Step 2 of the sequential analysis that governs Social Security cases, the ALJ found that Saltos had the following severe impairments: depression, anxiety with social phobia, obsessive compulsive disorder, and body dysmorphic disorder. (Id.)

The ALJ then concluded at Step 3 of this sequential analysis that none of Saltos’ impairments were per se disabling, and provided the following analysis in support of this conclusion: The severity of the claimant’s mental impairments, considered singly and in combination, do not meet or medically equal the criteria of listings 12.04 and 12.06. In making this finding, the undersigned has

1 We note that the ALJ’s decision seems, at times, to conflate adult and juvenile disability standards, but need not address this issue, which has not been highlighted by the parties, in light of our disposition of this case on other grounds.

4 considered whether the “paragraph B” criteria are satisfied. To satisfy the “paragraph B” criteria, the mental impairments must result in one extreme limitation or two marked limitations in a broad area of functioning. An extreme limitation is the inability to function independently, appropriately, or effectively, and on a sustained basis. A marked limitation is a seriously limited ability to function independently, appropriately, or effectively, and on a sustained basis.

In understanding, remembering or applying information, the claimant has no limitation. The claimant asserts that his conditions limited his ability to follow instructions, focus, concentrate, complete tasks, and manage his finances (Exhibit 6E). He also asserts that he needed special reminders to care for his personal needs and grooming, to take medications, and to go places (Exhibit 6E). However, the claimant failed to submit any evidence of mental status examinations that noted any significant limitation in his orientation, thought processing, judgment, or insight. Despite the fact that treatment records note the claimant had an Individualized Education Program (IEP) plan that allowed repetition of instructions, they do not note any significant and ongoing issues in the claimant’s ability to function in this area. Instead, the record notes that the claimant generally performed well in his academic course load with accommodations in place to address his concentration, social concerns, and anxiety (Exhibit 1F; 2F; 7F). Similarly, the claimant’s activities of daily living indicate the claimant is able to care for his personal needs and grooming, including his ability to dress, bathe, care for his hair, shave, feed himself, and use the bathroom (Exhibit 6E). He is also able to prepare meals on a regular basis and perform house and yard work, including mowing the lawn, vacuuming, and performing other chores (Exhibit 6E; Hearing Testimony). The claimant is able to go outside alone and shop in stores (Exhibit 6E). Given the overall evidence of record, the undersigned finds the claimant has no limitation in this functional area.

In interacting with others, the claimant has a moderate limitation.

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Saltos v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/saltos-v-omalley-pamd-2024.