Smith v. Dudek

CourtDistrict Court, E.D. Virginia
DecidedMarch 26, 2025
Docket3:24-cv-00068
StatusUnknown

This text of Smith v. Dudek (Smith v. Dudek) 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
Smith v. Dudek, (E.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division

LINDA S.,1 ) ) Plaintiff, ) ) v. ) Civil No. 3:24-cv-0068-SLS ) LELAND DUDEK,2 ) Acting Commissioner of Social Security, ) ) Defendant. ) _______________________________________)

MEMORANDUM OPINION In this action, Plaintiff Linda S. seeks review of the Commissioner of the Social Security Administration’s (“SSA”) decision to deny her Title II application for disability insurance benefits. This matter comes before the Court on cross-motions for summary judgment, which have been fully briefed, making this matter ripe for review. (ECF Nos. 13, 14, 15, 18.) The Court exercises jurisdiction with the consent of the parties pursuant to 28 U.S.C. § 636(c)(1) (ECF Nos. 12, 16, 20) and pursuant to 42 U.S.C. § 405(g). Plaintiff moves the Court to reverse the Commissioner’s decision and order payment of Social Security benefits. (Plaintiff’s Brief in Support of Motion for Summary Judgment (ECF No. 14) (“Pl.’s Br.”) at 23.3) In the alternative, Plaintiff seeks a remand for further proceedings. (Pl.’s

1 The Committee on Court Administration and Case Management of the Judicial Conference of the United States has recommended that federal courts refer to claimants by their first names and last initials in social security cases. 2 Leland Dudek became the Acting Commissioner of Social Security in February 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, he has been substituted for the former Commissioner as Defendant in this action. No further action need be taken. 42 U.S.C. § 405(g). 3 The Court uses the pagination in the underlying documents rather than the pagination generated by CM/ECF. Br. at 23.) As the basis for relief, Plaintiff argues that the Administrative Law Judge (“ALJ”) erred as a matter of law by: (1) failing to account for Plaintiff’s mental limitations in (a) adapting and managing oneself and (b) concentrating, persisting, and maintaining pace in the residual functional capacity (“RFC”) assessment (Pl.’s Br. at 10-18); and (2) failing to develop the record by

subpoenaing Plaintiff’s mental health treatment records from Kimberly Chandler-Holt, Plaintiff’s former therapist (Pl.’s Br. at 18-23). In response, the Commissioner argues that the ALJ fully considered Plaintiff’s non-severe mental limitations in determining the RFC and adequately developed the record. (Defendant’s Motion for Summary Judgment and Brief in Support Thereof (ECF No. 15) (“Def.’s Br.”) at 9-18.) Therefore, the Commissioner asks the Court to affirm his final decision. (Def.’s Br. 18.) For the reasons set forth below, the Court finds that: (1) the ALJ applied correct legal standards in considering Plaintiff’s mental limitations, and substantial evidence supports the RFC determination; and (2) the ALJ properly developed the administrative record in accordance with applicable law. Therefore, the Court will DENY Plaintiff’s Motion for Summary Judgment (ECF

No. 13), GRANT the Commissioner’s Motion for Summary Judgment (ECF No. 15), and AFFIRM the final decision of the Commissioner. I. PROCEDURAL HISTORY On June 12, 2020, Plaintiff filed a Title II application for disability insurance benefits, alleging disability beginning on December 31, 2018. (Administrative Record (“R.”) at 62, 64.)4 In her application, Plaintiff alleged that she suffers from back problems, high blood pressure,

4 The administrative record in this case remains filed under seal, pursuant to E.D. Va. Loc. R. 5 and 7(C). In accordance with these rules, the Court will exclude personal identifiers from this Memorandum Opinion. The Court will further restrict its discussion of Plaintiff’s medical information to the extent necessary to result in a proper analysis of the case. “[e]sclorisis,” a herniated disc, and arthritis. (R. at 64.) Plaintiff’s application for benefits was denied, both initially and upon reconsideration. (R. at 62, 78.) Plaintiff requested a hearing before an ALJ, and one was held on June 8, 2023. (R. at 45-61, 104.) On July 6, 2023, the ALJ issued a written decision, finding Plaintiff disabled under the

Social Security Act (“the Act”) beginning January 16, 2023, but not disabled prior to that date. (R. at 23-35.) On August 15, 2023, the SSA Appeals Council denied Plaintiff’s request for review, rendering the ALJ’s decision the final decision of the Commissioner. (R. at 7-9.) Plaintiff now seeks judicial review pursuant to 42 U.S.C. § 405(g). II. STANDARD OF REVIEW The Act defines a disability as the “inability 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). An individual has a disability “only if his [or her] physical or mental impairment or impairments are of such severity that he [or she] is not only

unable to do his [or her] previous work but cannot, considering his [or her] age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy. . . .” Id. § 423(d)(2)(A). SSA regulations set forth a five-step process to determine whether an individual is disabled. 20 C.F.R. § 404.1520(a)(4); see Mascio v. Colvin, 780 F.3d 632, 634-35 (4th Cir. 2015) (describing the ALJ’s five-step sequential evaluation). At step one, the ALJ reviews the claimant’s current work activity to determine if he or she has been participating in substantial gainful activity. 20 C.F.R. § 404.1520(a)(4)(i). At step two, the ALJ asks whether the claimant’s medical impairments meet the regulations’ severity and duration requirements. Id. § 404.1520(a)(4)(ii). At step three, the ALJ determines whether the medical impairments meet or equal an impairment listed in the regulations. Id. § 404.1520(a)(4)(iii). Between steps three and four, the ALJ determines the claimant’s RFC, which accounts for the most the claimant can do despite his or her impairments. Id. § 404.1545(a).

At step four, the ALJ assesses whether the claimant can perform his or her past employment given his or her RFC. Id. § 404.1520(a)(4)(iv). The burden of proof remains with the claimant through step four of the analysis, and the claimant must prove that his or her limitations preclude the claimant from performing his or her past relevant work. See Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987); Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012). If such past work can be performed, then benefits will not be awarded, and the analysis ends. See 20 C.F.R. § 404.1520(e).

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Smith v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/smith-v-dudek-vaed-2025.