SCHAEFFER v. SAUL

CourtDistrict Court, E.D. Pennsylvania
DecidedNovember 30, 2023
Docket5:21-cv-03081
StatusUnknown

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

Bluebook
SCHAEFFER v. SAUL, (E.D. Pa. 2023).

Opinion

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

STEPHEN DAVID SCHAEFFER, : CIVIL ACTION : v. : : KILOLO KIJAKAZI,1 : No. 21-cv-3081 Acting Commissioner of Social : Security.

MEMORANDUM OPINION

CRAIG M. STRAW November 30, 2023 United States Magistrate Judge

Stephen David Schaeffer seeks review of the Commissioner’s decision denying his application for Disability Insurance Benefits (DIB) and Supplemental Social Security (SSI) benefits. The parties consented to proceed before a Magistrate Judge2 and the matter was assigned to me.3 For the following reasons, I deny Schaeffer’s request for review and affirm the Commissioner’s decision.

1 Kilolo Kijakazi is now the Acting Commissioner of Social Security. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, she should be substituted for Andrew Saul as Defendant in this suit. See also 42 U.S.C. § 405(g) (stating “[a]ny action instituted in accordance with this subsection shall survive notwithstanding any change in the person occupying the office of the Commissioner of Social Security or any vacancy in such office.”) 2 See Docs. 9 & 20; 28 U.S.C. § 636(c) & Fed. R. Civ. P. 73. 3 I was reassigned the case from Magistrate Judge David R. Strawbridge on July 27, 2023. Doc. 18. I. PROCEDURAL HISTORY On August 11, 2016, Schaeffer filed an application for DIB and SSI benefits under the Social Security Act. R. 121; 132; 332-46. In his application, Schaeffer asserted his disabling condition began around February 11, 2016.4 R. 49; 59; 122; 132; 332; 339. The claims were denied initially on December 13, 2016. R. 167; 172. Schaeffer filed a request for a hearing. R. 177. A video hearing took place on May 24, 2018 before an ALJ presiding from the National Hearing Center in Baltimore, Maryland. R. 69; 146. Schaeffer appeared in Reading, Pennsylvania. R. 71; 146. The ALJ informed Schaeffer of his right to counsel at the hearing, but Schaeffer elected to proceed pro se. R. 78; 146. The ALJ denied benefits. R. 143; 146-57; 162. Schaeffer filed a request for review, alleging the ALJ decision was not based on substantial evidence because Schaeffer was unrepresented, and the medical record was not

complete when the ALJ decided the case. R. 162; 223. Schaeffer also filed an appointment of representation form, along with a fee agreement between Schaeffer and his attorney. R. 217-20. The Appeals Council granted the request for review, vacated the ALJ decision, and remanded the case to resolve several issues. R. 162-64.

4 The ALJ’s decision provides that Schaeffer’s alleged onset disability (AOD) date is March 1, 2017. R. 12; 15; 33. During the hearing, however, the ALJ said to Schaeffer’s attorney, Barbara Feudale, “All right, Ms. Feudale, with regards to the onset date, it looks like we have a[n] onset of February of ‘16. That’s -- is that the date that we’re working from?” Ms. Feudale responded “Yes, ma’am.” R. 49. Several documents in the record also support an AOD of February 11, 2016. See R. 49; 59; 122; 132; 213; 332; 339. Therefore, for the purpose of evaluating Schaeffer’s disability claims, I consider the medical evidence in the record beginning on February 11, 2016. 2 First, the Appeals Council directed the ALJ to obtain additional medical evidence from Schaeffer’s primary mental health treatment sources and consider the limitations proposed by Dr. Amanda Kochan-Dewey, Psy.D., because the ALJ afforded her opinion substantial weight. R. 162. The Appeals Council also ordered the ALJ to obtain more evidence regarding Schaeffer’s impairments to complete the administrative record. R. 163. Furthermore, the ALJ was to evaluate Schaeffer’s mental impairments according to the special technique set forth in 20 C.F.R. § 404.1520a and 416.920a and make specific findings for each functional area. Id. The ALJ also had to determine Schaeffer’s limitations and residual functional capacity (RFC), evaluate the treating and non-treating source opinions, and decide what weight to give each opinion. Id. Finally, if necessary, the ALJ was directed to obtain supplemental evidence from the VE to clarify the effect of the assessed limitations on Schaeffer’s occupational base as well as identify jobs in the national economy that Schaeffer could perform. Id.

A second hearing was held on October 14, 2020 before a different ALJ, Margaret M. Gabell. R. 44. Because of the COVID-19 Pandemic, all the parties, including VE Daniel Rappucci and counsel for Schaeffer, participated by telephone. Id. The ALJ denied benefits on October 27, 2022. R. 9-34. Schaeffer filed a request for review of the ALJ’s decision and a hearing, which were denied. R. 1; 5; 7; 330. Thus, the ALJ’s decision became the final decision of the Commissioner of Social Security. R. 1-3; 20 C.F.R. §§ 404.981, 416.1481. Schaeffer’s counsel then filed this action in federal court. Doc. 2. Schaeffer, through counsel, filed Plaintiff’s Brief and Statement of Issues in Support of Request for Review. Doc. 10. Defendant filed a Response to Plaintiff’s Request for Review. Doc. 17. No reply brief was filed.

3 II. LEGAL STANDARDS To prove disability, a claimant must demonstrate an “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment . . . which has lasted or can be expected to last for a continuous period of not less than 12 months . . . .” 42 U.S.C. § 423(d)(1)(A). The Commissioner employs a five-step sequential process to determine if a claimant is disabled, evaluating: 1. Whether the claimant is currently engaged in substantial gainful activity;

2. If not, whether the claimant has a “severe impairment” that significantly limits their physical or mental ability to perform basic work activities;

3. If so, whether based on the medical evidence, the impairment meets or equals the criteria of an impairment listed in the listing of impairments (“Listings,” see 20 C.F.R. pt. 404, subpt. P, app. 1), which results in a presumption of disability;

4. If the impairment does not meet or equal the criteria for a listed impairment, whether, despite the severe impairment, the claimant has the RFC to perform their past work; and

5. If the claimant cannot perform their past work, whether there is other work in the national economy that the claimant can perform.

See Zirnsak v. Colvin, 777 F.3d 607, 611 (3d Cir. 2014); see also 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4). Plaintiff bears the burden of proof at steps one through four, while the burden shifts to the Commissioner at step five to establish that the claimant can perform other jobs in the local and national economies based on their age, education, work experience, and RFC. See Poulos v. Comm’r of Soc. Sec., 474 F.3d 88, 92 (3d Cir. 2007). The court’s role on judicial review is to determine whether the Commissioner’s decision is supported by substantial evidence.

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SCHAEFFER v. SAUL, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schaeffer-v-saul-paed-2023.