Scott v. Dudek

CourtDistrict Court, S.D. West Virginia
DecidedMarch 28, 2025
Docket2:24-cv-00050
StatusUnknown

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

Bluebook
Scott v. Dudek, (S.D.W. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA

CHARLESTON DIVISION

LINDA S.,

Plaintiff,

v. CIVIL ACTION NO. 2:24-cv-00050

LELAND DUDEK, Acting Commissioner for the Social Security Administration,

Defendant.

MEMORANDUM OPINION AND ORDER

Pending before the Court is Linda S.’s (“Claimant”) Complaint seeking review of the final decision of the Acting Commissioner of Social Security, Leland Dudek1 (“Commissioner”). (ECF No. 1.) By Standing Order, this action was referred to United States Magistrate Judge Omar J. Aboulhosn (“Magistrate Judge”) for submission of proposed findings and a recommendation (“PF&R”). (ECF No. 2.) Magistrate Judge Aboulhosn filed his PF&R on May 10, 2024, (ECF No. 10), recommending that this Court deny the Claimant’s motion for judgment on the pleadings, (ECF No. 5), grant the Commissioner’s motion for judgment on the pleadings, (ECF No. 8), affirm the final decision of the Commissioner, and dismiss this action from the Court’s docket. Claimant timely filed her objections to the PF&R on June 12, 2024, (ECF No. 11), and the Commissioner timely responded, (ECF No. 12). For the reasons that follow, the Court

1 While Martin J. O’Malley was the Acting Commissioner of Social Security when Claimant commenced this action, Leland Dudek became the Acting Commissioner on February 17, 2025. Acting Commissioner Dudek is automatically substituted as the defendant in this action. Fed. R. Civ. P. 25. OVERRULES Claimant’s Objections, (ECF No. 11), ADOPTS the PF&R, (ECF No. 10), and DISMISSES this action from the Court’s docket. I. BACKGROUND A detailed recitation of the extensive facts of this action can be found in the Magistrate Judge’s PF&R, (Id.), and therefore need not be repeated here. The Court will provide a discussion

of any relevant facts as necessary throughout this opinion to resolve Claimant’s objections. II. LEGAL STANDARD A. Review of a Magistrate Judge’s PF&R The Court is required to “make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1)(C). However, the Court is not required to review, under a de novo or any other standard, the factual or legal conclusions of the Magistrate Judge as to any portion of the findings or recommendation to which no objections are addressed. Thomas v. Arn, 474 U.S. 140, 150 (1985). Further, this Court need not conduct a de novo review of any “general and conclusory

objections that do not direct the Court to a specific error in the magistrate’s proposed findings and recommendations.” Orpiano v. Johnson, 687 F.2d 44, 47 (4th Cir. 1982). B. Review of the ALJ’s Findings and Decision The Court’s review of a final disability benefits decision is limited to determining whether the Administrative Law Judge’s (“ALJ”) findings are supported by substantial evidence and whether the correct law was applied. See 42 U.S.C. § 405(g) (“The findings of the Secretary as to any fact, if supported by substantial evidence, shall be conclusive . . . .”); see also Coffman v. Bowen, 829 F.2d 514, 517 (4th Cir. 1987) (“A factual finding by the ALJ is not binding if it was

2 reached by means of an improper standard or misapplication of the law.”). The substantial evidence required to support an ALJ’s finding must be more than a scintilla of evidence, but can be less than a preponderance of the evidence. Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001). “It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Consol. Edison Co. v. NLRB, 305 U.S. 197, 229 (1938). “In reviewing for

substantial evidence, [the court should] not undertake to reweigh conflicting evidence, make credibility determinations, or substitute [its] judgment for that of the [ALJ].” Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996). The Court must defer to the Commissioner’s decision if “conflicting evidence allows reasonable minds to differ as to whether a claimant is disabled.” Id. (citing Walker v. Bowen, 834 F.2d 635, 640 (7th Cir. 1987)). A claimant bears the burden of proving to the Commissioner that she is disabled within the meaning of the Social Security Act. 42 U.S.C. § 423(d)(5). To be “disabled” means a claimant is unable “to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment 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 12 months.” 42 U.S.C. § 423(d)(1)(A). To assess a disability claim, the Commissioner must follow a five-step “sequential evaluation” process. See 20 C.F.R. §§ 404.1520(a) & 416.920(a)(4). The Fourth Circuit has provided the following description of that process: Under the process the ALJ must determine in sequence: (1) whether the claimant is currently engaged in substantial gainful activity; (2) if not, whether [s]he has a severe impairment; (3) if so, whether that impairment meets or equals the medical criteria of Appendix 1 which warrants a finding of disability without considering vocational factors; and (4) if not, whether the impairment prevents [her] from performing [her] past relevant work. By satisfying either step 3 or 4, the claimant establishes a prima facie case of disability. The burden then shifts to the Secretary and leads to the fifth and final inquiry in the sequence: whether the claimant is able 3 to perform other work considering both [her] remaining physical and mental capacities (defined as residual functional capacity) and [her] vocational capabilities (age, education, and past work experience) to adjust to a new job.

Hall v. Harris, 658 F.2d 260, 264–65 (4th Cir. 1981); see also 20 C.F.R. §§ 404.1520 & 416.920 (providing the “sequential evaluation” analysis). The claimant bears the burden of proof at steps one through four, but the burden shifts to the Commissioner at step five. See Pass v. Chater, 65 F.3d 1200, 1203 (4th Cir. 1995). If a disability decision can be made at any step of the process, the inquiry ceases. See 20 C.F.R.

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Scott v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/scott-v-dudek-wvsd-2025.