Sandra A. o/b/o E.G.A. v. Commissioner of Social Security

CourtDistrict Court, W.D. New York
DecidedMarch 26, 2026
Docket6:24-cv-06474
StatusUnknown

This text of Sandra A. o/b/o E.G.A. v. Commissioner of Social Security (Sandra A. o/b/o E.G.A. v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, W.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sandra A. o/b/o E.G.A. v. Commissioner of Social Security, (W.D.N.Y. 2026).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF NEW YORK

SANDRA A. o/b/o E.G.A.,! Plaintiff, v. 24-CV-6474-MAV DECISION AND ORDER COMMISSIONER OF SOCIAL SECURITY, Defendant.

INTRODUCTION Sandra A. (“Plaintiff”) brought this action pursuant to 42 U.S.C. § 405(g) to review the final determination of the Commissioner of the United States Social Security Administration (“Commissioner”), denying her application for Supplemental Security Income (“SSI”) on behalf of her minor child, E.G.A. See ECF No. 1; 42 U.S.C. §§ 405(g). The parties filed cross-motions for judgment on the pleadings pursuant to Rule 12(c) of the Federal Rules of Civil Procedure. ECF Nos. 8, 10. Plaintiff filed a reply. ECF No. 12. For the reasons set forth below, the Court grants Plaintiffs motion, ECF No. 8, and denies the Commissioner’s cross-motion, ECF No. 10.

1 The Court’s Standing Order issued on November 18, 2020, directs that “in opinions filed pursuant to 42 U.S.C. § 405(g), in the United States District Court for the Western District of New York, any non-governmental party will be identified and referenced solely by first name and last initial.”

PROCEDURAL HISTORY The Court assumes the reader’s familiarity with the facts and procedural history in this case and therefore addresses only those facts and issues which bear directly on the resolution of the motions presently before the Court. I. Plaintiff's Application On March 14, 2022, Plaintiff filed an application for SSI on behalf of E.G.A., alleging a disability onset date of March 9, 2021, due to trauma and stressor-related disorder, oppositional defiance disorder, attention deficit hyperactivity disorder (“ADHD”), anxiety disorder, and hearing loss. Administrative Record (“AR”) at 164— 69, 176, 1938-201, 222-26, 229-33.2 The claim was initially denied by the Social Security Administration (“SSA”) in July 2022 and on reconsideration in March 2023. Id. at 17, 52-69. Thereafter, Plaintiff timely requested a hearing. Id. at 92-93. Il. Plaintiff's Hearing Before the ALJ On September 19, 2023, an Administrative Law Judge (“ALJ”) held a hearing during which Plaintiff testified telephonically. Id. at 17, 28, 31. E.G.A. was born in 2010 and was a school-aged child at the time of his application and hearing. Id. at 37, 174. E.G.A. has no work history. Jd. at 173. Plaintiff was represented by a non- attorney representative. Id. at 17, 30-32. Plaintiff testified that what caused her to file the SSI application on behalf of her son was him experiencing “a lot of anxiety and abuse around that time. The person that was [responsible for] his care abused

2 When referencing the page number(s) of citations to the administrative record in this Decision and Order, the Court cites to the SSA citations located at the bottom right of the papers.

him. And as of right now, he’s in therapy with a psychiatrist. And in May and June 2021, he was involved in a hit and run. And after that hit and run, he [doesn’t] think the same. He [doesn’t] make good choices like he used to.” Id. at 39. II. The ALJ’s Decision Individuals under eighteen (18) years old are considered disabled when the individual “has a medically determinable physical or mental impairment, which results in marked and severe functional limitations, and 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 twelve months.” 42 U.S.C. § 1882c(a)(3)(C)G). In evaluating disability claims in children, the Commissioner is required to use the three-step process promulgated in 20 C.F.R. § 416.924. The first step requires the ALJ to determine whether the child is engaged in “substantial gainful activity.” See 20 C.F.R. § 416.924(a). Here, the ALJ found E.G.A. had not been engaged in substantial gainful activity since March 14, 2022—the date of the SSI application.? AR at 18. The second step requires the ALJ to determine whether the child has any severe impairments, defined as anything that causes “more than minimal functional limitations.” 20 C.F.R. § 416.924(a), (c). Here, the ALJ found E.G.A. had the following severe impairments: ADHD, anxiety disorder, and hearing loss. AR at 18.

3 The earliest month for which SSI can be paid is the month following the month in which the application was filed. 20 C.F.R. § 416.335.

Finally, the ALJ determines whether the child’s impairment or combination of impairments meets, medically equals, or functionally equals the severity of a listed impairment. Tyler J. o/b/o R.D. v. Comm of Soc. Sec., No. 1:20-CV-899-DB, 2024 WL 475067, at *1—-2 (W.D.N_Y. Feb. 7, 2024) (citing 20 C.F.R. §§ 416.925, 416.926). If the ALJ finds that the child’s impairment or combination of impairments meets or equals a listing, the child is then considered disabled. 20 C.F.R. § 416.924(d)(1). If not, the ALJ must assess the “functional equivalence” of the limitation or limitations in six domains of functioning: 1. Acquiring and using information; 2. Attending and completing tasks; 3. Interacting and relating with others; 4. Moving about and manipulating objects; 5. Caring for yourself; and 6. Health and physical well-being. Id. at § 416.926a(b)(1); see, e.g., Andrea L. H. 0/b/o M.E.O. v. Comm’ of Soc. Sec., No. 1:19-CV-01816(JJM), 2021 WL 9595952, at *8 (W.D.N.Y. Mar. 24, 2021). When determining functional equivalence, the “whole child” must be considered, by considering how the child functions at home, at school, and in the community; the interactive and cumulative effects of all of the child’s medically determinable impairments on the child’s activities; and the type, extent, and frequency of help the child needs. Social Security Ruling (“SSR”) 09-1p, Title XVI: Determining Childhood Disability Under the Functional Equivalence Rule — The “Whole Child” Approach, 74 Fed. Reg. 7527 (S.S.A. Mar. 19, 2009); Hicks 0/b/o A.D.H. v. Comm’ of Soc. Sec., No. 18-cv-00467, 2020 WL 1061488, at *6 (W.D.N.Y. Mar. 5, 2020) (“The SSR is clear that there is a ‘whole child’ approach for determining functional equivalency and that

the rating of limitation of a domain is not an ‘average’ of what activities the child can and cannot do.” (citing SSR 09-1p)); Carrera v. Colvin, No. 1:13-cv-1414, 2015 WL 1126014, at *8 (N.D.N.Y. Mar. 12, 2015). “All of the relevant evidence includes objective medical evidence and other relevant evidence from medical sources; information from other sources, such as school teacher[s], family members, or friends; the claimant’s statement (including statements from the claimant's parent(s) or other caregivers); and any other relevant evidence in the case record, including how claimant functions over time and in all settings (G.e., at home, at school, and in the community).” Carrera, 2015 WL 1126014, at 3, n.8; accord SSR 2009-2p, 2009 SSR LEXIS 2, *7 (SSA Feb.

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Bluebook (online)
Sandra A. o/b/o E.G.A. v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sandra-a-obo-ega-v-commissioner-of-social-security-nywd-2026.