Schain v. Dudek

CourtDistrict Court, E.D. North Carolina
DecidedSeptember 23, 2025
Docket2:24-cv-00036
StatusUnknown

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

Bluebook
Schain v. Dudek, (E.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA NORTHERN DIVISION No. 2:24-CV-36-BM

DAVID SCHAIN, ) ) Plaintiff, ) ) v. ) ORDER ) FRANK BISIGNANO, ) Commissioner of Social Security, ) ) Defendant. )

Plaintiff David Schain (“Plaintiff” or, in context, “Claimant”) filed this action pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3) seeking judicial review of the denial of his application for a period of disability, disability insurance benefits (“DIB”), and supplemental security income (“SSI”). This matter is before the court on Plaintiff’s brief [DE-12] (“Pl.’s Brief”) seeking judgment in his favor, Defendant’s responsive brief [DE-14] (“Def.’s Brief”) in opposition, and Plaintiff’s reply brief [DE-15] (“Pl.’s Reply”). The parties have fully briefed this matter pursuant to the Supplemental Rules for Social Security Actions under 42 U.S.C. § 405(g), and this case is ripe for adjudication. The parties have consented to entry of final judgment by a United States magistrate judge under 28 U.S.C. § 636(c), with any appeal to the Court of Appeals for the Fourth Circuit. Having reviewed and considered the record, the administrative transcript, the briefs submitted by the parties, and the applicable law, the court denies Plaintiff’s brief [DE-12], allows Defendant’s brief [DE-14], and affirms the final decision of the Commissioner. I. STATEMENT OF THE CASE Plaintiff protectively filed an application for a period of disability and DIB on September 11, 2020, and filed an application for a period of disability and SSI on May 17, 2023, in each case alleging disability beginning September 27, 2019. Transcript of Proceedings (“Tr.”) 17, 116, 300- 01. Plaintiff’s DIB claim was denied initially. Tr. 116-26, 169-78. Plaintiff filed a request for reconsideration (Tr. 179-80), and was denied upon reconsideration on April 20, 2022 (Tr. 138, 181- 90). On April 21, 2022, Plaintiff requested a hearing before the Administrative Law Judge

(“ALJ”). Tr. 191-93. A hearing before the ALJ was held on June 21, 2023, at which Plaintiff, represented by a non-attorney representative, and a vocational expert (“VE”) appeared and testified. Tr. 42-85. Plaintiff’s mother, Patricia Schain, also appeared and testified during the hearing. Tr. 69-75. On September 7, 2023, the ALJ issued a decision denying Plaintiff’s request for benefits. Tr. 14-41. On September 21, 2023, Plaintiff requested a review of the ALJ’s decision by the Appeals Council. Tr. 277-79. On June 17, 2024, the Appeals Council denied Plaintiff’s request for review. Tr. 1-6. Plaintiff then filed a complaint in this court seeking review of the now-final administrative decision. II. STANDARD OF REVIEW

The scope of judicial review of a final agency decision regarding disability benefits under the Social Security Act (“Act”), 42 U.S.C. § 301 et seq., is limited to determining whether substantial evidence supports the Commissioner’s factual findings and whether the decision was reached through the application of the correct legal standards. See Coffman v. Bowen, 829 F.2d 514, 517 (4th Cir. 1987). “The findings of the Commissioner . . . as to any fact, if supported by substantial evidence, shall be conclusive . . . .” 42 U.S.C. § 405(g). Substantial evidence is “evidence which a reasoning mind would accept as sufficient to support a particular conclusion.” Laws v. Celebrezze, 368 F.2d 640, 642 (4th Cir. 1966). While substantial evidence is not a “large or considerable amount of evidence,” Pierce v. Underwood, 487 U.S. 552, 565 (1988), it is “more 2 than a mere scintilla . . . and somewhat less than a preponderance.” Laws, 368 F.2d at 642. “In reviewing for substantial evidence, [the court should not] undertake to re-weigh conflicting evidence, make credibility determinations, or substitute [its] judgment for that of the [Commissioner].” Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001) (quoting Craig v. Chater, 76

F.3d 585, 589 (4th Cir. 1996), superseded by regulation on other grounds, 20 C.F.R. § 416.927(d)(2)). Rather, in conducting the “substantial evidence” inquiry, the court’s review is limited to whether the ALJ analyzed the relevant evidence and sufficiently explained his or her findings and rationale in crediting the evidence. Sterling Smokeless Coal Co. v. Akers, 131 F.3d 438, 439-40 (4th Cir. 1997). “Judicial review of an administrative decision is impossible without an adequate explanation of that decision by the administrator.” DeLoatche v. Heckler, 715 F.2d 148, 150 (4th Cir. 1983). III. DISABILITY EVALUATION PROCESS The disability determination is based on a five-step sequential evaluation process as set forth in 20 C.F.R. §§ 404.1520 and 416.920 under which the ALJ is to evaluate a claim:

The claimant (1) must not be engaged in “substantial gainful activity [“SGA”],” i.e., currently working; and (2) must have a “severe” impairment that (3) meets or exceeds [in severity] the “listings” of specified impairments, or is otherwise incapacitating to the extent that the claimant does not possess the residual functional capacity [“RFC”] to (4) perform . . . past work or (5) any other work.

Albright v. Comm’r of the Soc. Sec. Admin., 174 F.3d 473, 475 n.2 (4th Cir. 1999). “If an applicant’s claim fails at any step of the process, the ALJ need not advance to the subsequent steps.” Pass v. Chater, 65 F.3d 1200, 1203 (4th Cir. 1995) (citation omitted). The burden of proof and production during the first four steps of the inquiry rests on the claimant. Id. At the fifth step, the burden shifts to the ALJ to show that other work exists in the national economy which the claimant can perform. Id. 3 When assessing the severity of mental impairments, the ALJ must do so in accordance with the “special technique” described in 20 C.F.R. §§ 404.1520a(b)-(c) and §§ 416.920a(b)-(c). This regulatory scheme identifies four broad functional areas in which the ALJ rates the degree of functional limitation resulting from a claimant’s mental impairment(s): understanding,

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Schain v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schain-v-dudek-nced-2025.