Slaughter v. Commissioner of Social Security

CourtDistrict Court, E.D. Virginia
DecidedOctober 12, 2021
Docket1:21-cv-00096
StatusUnknown

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

Bluebook
Slaughter v. Commissioner of Social Security, (E.D. Va. 2021).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Alexandria Division MALCOM S., ) ) Plaintiff, ) ) Vv. ) Civil Action No. 1:21¢v0096 (RDA/JFA) ) KILOLO KIJAKAZI, ) Acting Commissioner of Social Security, ) ) Defendant. ) a)

REPORT AND RECOMMENDATION This matter is before the undersigned magistrate judge for a report and recommendation pursuant to 28 U.S.C. § 636(b)(1)(B) on cross-motions for summary judgment. (Docket nos. 17, 20). Pursuant to 42 U.S.C. § 405(g), plaintiff seeks judicial review of the final decision of Kilolo Kijakazi, Acting Commissioner of the Social Security Administration (“Commissioner”), denying plaintiff's claim for disability insurance benefits (“DIB”) and Supplemental Security Income (“SSI”) under the Social Security Act. The Commissioner’s final decision is based on a finding by the Administrative Law Judge (“ALJ”) and Appeals Council for the Office of Appellate Operations (“Appeals Council”) that plaintiff was not disabled as defined by the Social Security Act and applicable regulations.'

' The Administrative Record (“AR”) in this case has been filed under seal, pursuant to Local Civil Rules 5 and 7(C). (Docket no. 14). In accordance with those rules, this report and recommendation excludes any personal identifiers such as plaintiff's social security number and date of birth (except for the year of birth), and the discussion of plaintiff’s medical information is limited to the extent necessary to analyze the case.

I. PROCEDURAL BACKGROUND Plaintiff applied for DIB and SS] initially alleging a disability onset date of December 15, 2017. (AR 258-70). The Social Security Administration (“SSA”) denied plaintiff's applications on June 15, 2018. (AR 133-35). On June 22, 2018, plaintiff signed an “Appointment of Representative” form authorizing Andrew Mathis to represent him with respect to his claims. (AR 139). Plaintiff requested reconsideration of the denials on June 25, 2018, (AR 141), and the SSA affirmed its denial on September 17, 2018. (AR 142-55). On September 25, 2018, plaintiff requested a hearing before an ALJ. (AR 156-57). The Office of Hearings Operations acknowledged receipt of plaintiff's request on October 5, 2018, (AR 158-63), and scheduled a hearing before an ALJ for March 13, 2020. (AR 180-208). On February 27, 2020, plaintiff withdrew his request for a hearing. (AR 211). On March 6, 2020, plaintiff's representative, Mr. Mathis, indicated that plaintiff wished to rescind the withdrawal of his request for a hearing. (AR 220). Mr. Mathis also stated that plaintiff had discharged him from representation.? Jd. On March 13, 2020, ALJ George Gaffaney held a virtual hearing. (AR 37-48). Plaintiff appeared without representation and was granted a continuance to secure representation. (AR 41, 46). On March 16, 2020, plaintiff signed another “Appointment of Representation” form, again authorizing Andrew Mathis to represent him with respect to his claims. (AR 223). On June 3, 2020, the Office of Hearings Operations scheduled another hearing before ALJ Gaffaney for July 15, 2020. (AR 227-51). On July 14, 2020, plaintiff amended his alleged onset date of disability to April 1, 2020. (AR 297). On July 15, 2020, ALJ Gaffaney held a second virtual hearing. (AR 49-74). Plaintiff appeared with Mr. Mathis as his representative. (AR 51). Plaintiff provided testimony and

2 This was also reflected in a letter from plaintiff, dated March 4, 2020. (AR 218).

answered questions posed by the ALJ, a vocational expert, and his representative. (AR 54-66). The vocational expert also answered questions from the ALJ and plaintiff's representative. (AR 61-71). On August 18, 2020, the ALJ issued his decision finding that plaintiff was not disabled under sections 216(i), 223(d), and 1614(a)(3)(A) of the Social Security Act from April 1, 2020 through the date of his decision. (AR 17-27). That same day, plaintiff sent a request for review of the ALJ’s decision to the Appeals Council. (AR 254-57). On August 19, 2020, the Appeals Council granted plaintiff an extension of twenty-five (25) days to supplement his request for review. (AR 9-10). The Appeals Council denied the request for review on November 23, 2020, finding no reason under its rules to review the ALJ’s decision. (AR 1-3). As a result, the ALJ’s decision became the final decision of the Commissioner. (AR 1); see 20 C.F.R. §§ 404.981, 416.1481. Plaintiff was given sixty (60) days to file a civil action challenging the decision. (AR 2); see 20 C.F.R. §§ 404.981, 416.1481. Plaintiff requested an extension to file his civil action on December 16, 2020. (AR 7-8). On January 25, 2021, plaintiff filed this civil action seeking judicial review of the Commissioner’s final decision pursuant to 42 U.S.C. § 405(g). (Docket no. 1). On June 4, 2021, the parties filed a joint motion to set a briefing schedule for the parties’ cross-motions for summary judgment, (Docket no. 15), which the court granted on June 21. (Docket no. 16). Plaintiff filed his motion for summary judgment on July 9, 2021. (Docket no. 17). The Commissioner filed her cross-motion for summary judgment on August 9, 2021. (Docket no. 20). The parties waived oral argument on their motions. (Docket nos. 19, 22). The case is now before the undersigned for a report and recommendation on the parties’ cross-motions for summary judgment. (Docket nos. 17, 20).

Il. STANDARD OF REVIEW Under the Social Security Act, the district court will affirm the Commissioner’s final decision “when an ALJ has applied correct legal standards and the ALJ’s factual findings are supported by substantial evidence.” Mascio v. Colvin, 780 F.3d 632, 634 (4th Cir. 2015) (quoting Bird v. Comm’r of Soc. Sec. Admin., 699 F.3d 337, 340 (4th Cir. 2012)). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001) (quoting Richardson v. Perales, 402 U.S. 389, 401 (1971)). It is “more than a mere scintilla of evidence but may be somewhat less than a preponderance.” /d. (internal quotations and citations omitted). In determining whether a decision is supported by substantial evidence, the court does not “undertake to re- weigh conflicting evidence, make credibility determinations, or substitute [its] judgment for that of the Secretary.” Jd. (alteration in original) (quoting Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996)). It is the ALJ’s duty, and not that of the reviewing court, to resolve evidentiary conflicts, and the ALJ’s decision must be sustained if supported by substantial evidence. Smith v. Chater, 99 F.3d 635, 638 (4th Cir. 1996). Il. FACTUAL BACKGROUND A.

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Slaughter v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/slaughter-v-commissioner-of-social-security-vaed-2021.