Sensenig v. O'Malley

CourtDistrict Court, M.D. Pennsylvania
DecidedMarch 24, 2025
Docket3:24-cv-00170
StatusUnknown

This text of Sensenig v. O'Malley (Sensenig 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
Sensenig v. O'Malley, (M.D. Pa. 2025).

Opinion

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

SCOTT SENSENIG, : Civil No. 3:24-CV-00170 : Plaintiff, : : v. : : LELAND DUDEK,1 : Acting Commissioner of Social Security : (Magistrate Judge Carlson) : Defendant. :

MEMORANDUM OPINION

I. Introduction In Scott Sensenig’s case the Administrative Law Judge (ALJ) was confronted with a record marked by conflicts and contradictions. These conflicts were exemplified by the medical opinion evidence which presented a sweeping array of mutually inconsistent and irreconcilable views concerning the degree to which Sensenig’s impairments were disabling. Ultimately the ALJ navigated this evidence by making a series of fact-bound determinations which led to the conclusion that

1Leland Dudek became the Acting Commissioner of Social Security on February 16, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Leland Dudek should be substituted for the previously named defendant in this suit. No further action need be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g).

1 Sensenig retained the ability to perform a range of light work confined to simple tasks. Based upon this determination, the ALJ found that Sensenig was not disabled

and denied his disability claim. Sensenig now appeals this decision arguing that the ALJ erred in evaluating the severity of his symptoms, an error which led to an erroneous assessment of his

residual functional capacity. Upon this backdrop, our review of this case is cabined and confined by the “substantial evidence” standard of review in Social Security cases, which is described by the Supreme Court in the following terms: The phrase “substantial evidence” is a “term of art” used throughout administrative law to describe how courts are to review agency factfinding. T-Mobile South, LLC v. Roswell, 574 U.S. ––––, ––––, 135 S. Ct. 808, 815, 190 L.Ed.2d 679 (2015). Under the substantial- evidence standard, a court looks to an existing administrative record and asks whether it contains “sufficien[t] evidence” to support the agency’s factual determinations. Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S. Ct. 206, 83 L.Ed. 126 (1938) (emphasis deleted). And whatever the meaning of “substantial” in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence, this Court has said, is “more than a mere scintilla.” Ibid.; see, e.g., Perales, 402 U.S. at 401, 91 S. Ct. 1420 (internal quotation marks omitted). It means—and means only—“such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Consolidated Edison, 305 U.S. at 229, 59 S. Ct. 206. See Dickinson v. Zurko, 527 U.S. 150, 153, 119 S. Ct. 1816, 144 L.Ed.2d 143 (1999) (comparing the substantial-evidence standard to the deferential clearly- erroneous standard).

2 Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019). Under this standard of review, we are obliged to affirm the decision of the administrative law judge (ALJ) once we

find that it is “supported by substantial evidence, ‘even [where] this court acting de novo might have reached a different conclusion.’” Monsour Med. Ctr. v. Heckler, 806 F.2d 1185, 1190–91 (3d Cir. 1986) (quoting Hunter Douglas, Inc. v. NLRB, 804

F.2d 808, 812 (3d Cir. 1986)). Here, after a review of the record, although a court reviewing the evidence de novo could have reached a different conclusion on Sensenig’s functional abilities, mindful of the fact that substantial evidence “means only—‘such relevant evidence

as a reasonable mind might accept as adequate to support a conclusion,’” Biestek, 139 S. Ct. at 1154, we find that substantial evidence supported the ALJ’s findings in this case. Therefore, for the reasons set forth below, we will affirm the decision of

the Commissioner denying this claim. II. Statement of Facts and of the Case

A. Background

The administrative record of Sensenig’s disability application reveals the following essential facts: On August 6, 2021, Sensenig applied for disability and disability insurance benefits pursuant to Title II of the Social Security Act alleging an onset of disability beginning July 18, 2021. (Tr. 17). According to Sensenig, he

3 was completely disabled due to the combined effects of obesity, degenerative disc disease of the thoracic and lumbar spine, COPD/asthma, hyperlipidemia,

sleepwalking disorder, depression, anxiety, PTSD, and alcohol use disorder. (Tr. 19). Sensenig was born on December 25, 1980, and was 40 years old on the alleged disability onset date, which is defined as a younger individual under the

Commissioner’s regulations. (Tr. 28). He had a high school education and prior employment in a number of heavy, semi-skilled vocations. (Id.) A. Sensenig’s Clinical History The medical evidence following Sensenig’s alleged onset date in July 2021

revealed that Sensenig, a veteran, received his primary physical and psychological health care through the Veterans Administration. (Tr. 303-1007). With respect to this treatment history, the ALJ aptly summarized Sensenig’s largely unremarkable

clinical record during the pertinent time frame as follows: On July 29, 2021, James Via, Psy.D., performed a telephone therapy family session with the claimant and his wife. The claimant reported no concerns regarding his mood with the exception of anxiety and frustration secondary to issue with his employer. Dr. Via noted the claimant’s mood as mildly anxious and fully alert and oriented with fair insight and judgment and no signs of impaired thought process, thought content, or perceptual disturbance. On August 5, 2021, the claimant reported improvement in terms of anxiety with no recent anxiety attacks since increasing his buspirone dose (Exhibit 4F). On October 21, 2021, Dr. Via noted that the claimant was discharged from therapy. The claimant reported no alcohol use since August 13, 2021, with an intent

4 to remain sober. He also reported noticeable improvement with medication. Dr. Via noted the claimant’s overall stability and that he made “significant progress” since starting treatment (Exhibit 5F).

On November 15, 2021, the claimant underwent trigger point injection (x4) in the left thoracic paraspinal muscle groups in the bilateral lumbar paraspinal muscle (Exhibit 7F).

On November 17, 2021, Karena Hammon, CRNP, performed a consultative physical examination of the claimant. She noted the claimant’s history of degenerative disc disease with his October 2020 MRIs showing multi-level mild degenerative disc disease with no disc protrusion, no significant spinal canal, and no neural foraminal stenosis at the lumbar spine and multi-level neural foraminal stenosis at the thoracic spine. The claimant reported using pain medication daily, as well as the use of an H-wave device and a TENs unit. His weight was noted at 190 pounds. He presented with a normal, unassisted gait. He had no difficulty with walking on heels and toes but lost his balance with attempting tandem walk. He was able to squat 50% of full. He presented with mild kyphosis at the thoracic spine region. He had negative straight leg raising bilaterally both seated and supine. He presented with his joint stable and non-tender.

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Related

Consolo v. Federal Maritime Commission
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Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Dickinson v. Zurko
527 U.S. 150 (Supreme Court, 1999)
Kacee Chandler v. Commissioner Social Security
667 F.3d 356 (Third Circuit, 2011)

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Sensenig v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sensenig-v-omalley-pamd-2025.