SPEAKS v. COMMISSIONER OF SOCIAL SECURITY

CourtDistrict Court, E.D. Pennsylvania
DecidedAugust 4, 2025
Docket2:22-cv-04707
StatusUnknown

This text of SPEAKS v. COMMISSIONER OF SOCIAL SECURITY (SPEAKS v. COMMISSIONER OF SOCIAL SECURITY) is published on Counsel Stack Legal Research, covering District Court, E.D. Pennsylvania primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
SPEAKS v. COMMISSIONER OF SOCIAL SECURITY, (E.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA _________________________________________ : CHANTE S., : CIVIL ACTION Plaintiff, : v. : : FRANK J. BISIGNANO,1 : Commissioner of Social Security, : No. 22-04707 Defendant. : ____________________________________:

MEMORANDUM OPINION PAMELA A. CARLOS U.S. MAGISTRATE JUDGE August 4, 2025

Plaintiff Chante S. (“Plaintiff”) appeals the Commissioner of Social Security’s final decision to deny her claim for benefits. She contends that her intellectual disability meets the requirements of the Listing of Impairments, and that her treating psychiatrist submitted a Medical Source Statement which, if properly credited, would compel the conclusion that she is disabled. However, she argues that the Administrative Law Judge’s (“ALJ”) analysis was erroneous in several respects. First, she argues that the ALJ entirely failed to analyze Section 12.05B of the Listing of Impairments and improperly rejected findings concerning her IQ scores. According to Plaintiff, the ALJ found her IQ scores were not reliable based on nothing more than “speculative inferences” drawn from the record—not from objective medical evidence. Next, Plaintiff argues that the ALJ improperly rejected the medical opinion of her treating psychiatrist, Nohazarahit Garcia, M.D., by mischaracterizing the limitations assessed by Dr. Garcia, and by ignoring the supporting explanations provided by Dr. Garcia throughout the opinion.

1 Frank J. Bisignano became the Commissioner of Social Security on May 6, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Frank J. Bisignano should be substituted as the 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). The Commissioner disagrees, arguing that the ALJ’s analysis was appropriate under the governing regulations. The Commissioner concedes that the ALJ did not explicitly identify Listing 12.05B in the Decision. However, the Commissioner emphasizes that the Listings are merely a regulatory device used to streamline the decision-making process, and Listing 12.05B is only met

if a claimant meets the criteria of all three of its subsections. In this instance, Plaintiff has failed to carry her burden, and the ALJ’s findings are amply supported by substantial evidence. In other words, the ALJ’s failure to identify the listing by name is at most harmless error. Finally, the Commissioner argues that the ALJ adequately explained why Dr. Garcia’s medical opinion was not persuasive, and Plaintiff’s “articulation” arguments must be rejected as nothing more than an improper request for the Court to reweigh the evidence. Given this, the Commissioner argues that the ALJ’s decision must be affirmed. For the reasons that follow, I will affirm the Commissioner’s decision, and Plaintiff’s request for review is denied. I. BACKGROUND

A. Factual and Procedural History. Plaintiff was born in January 1984, and was therefore 37 years old as of the date of the ALJ’s Decision R.192. She completed high school with special education services, see R.52-53, and previously worked as a shuttle bus driver. R.36. In May of 2020, Plaintiff filled applications for a period of Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”), alleging she became unable to work due to disabling conditions on March 20, 2020. R287-302. These claims were initially denied on February 17, 2021, and upon reconsideration on May 11, 2021. R.207-22, 225-34. Plaintiff then requested a hearing before an ALJ, see R.236-36, and a hearing was held on October 13, 2021, see 97-150 (“hearing transcript”). After the hearing, the ALJ issued a written decision on November 1, 2021 denying Plaintiff’s claim. R.21-42 (“ALJ Decision”). The Appeals Council denied Plaintiff’s subsequent request for review, meaning the ALJ’s written opinion became the final decision of the Commissioner. R.1-7. Plaintiff now timely appeals.2

B. ALJ’s Decision. The ALJ evaluated Plaintiff’s claims using the five-step sequential analysis set forth in the Social Security regulations.3 Beginning at step one, the ALJ determined that Plaintiff has not engaged in substantial gainful activity since March 20, 2020. R.26. At step two, the ALJ found that Plaintiff suffered from the following severe impairments: major depressive disorder, post-traumatic stress disorder (“PTSD”), anxiety disorder, learning disorder, and intellectual disability. R.26 (citing 20 CFR 404.1520(c) and 416.920(c)). The ALJ further noted that the medical evidence of record also references a diagnosis of alcohol use disorder in sustained full remission during the relevant period, and the observation that Plaintiff was diagnosed with various eyesight disorders. R.27 (citations omitted). However, the ALJ explained

that there is no evidence of any specific limitations arising out of these conditions, and the lack of treatment suggests that these conditions were sporadic or acute in nature. R.27. Moving on to step three, the ALJ concluded that none of Plaintiff’s impairments alone, or in combination, met or medically equaled the requirements of the impairments listed in the

2 The parties have consented to the jurisdiction of a United States Magistrate Judge to conduct all proceedings, including the entry of a final judgment, pursuant to 28 U.S.C § 636(c). See ECF Doc. No. 12. 3 The sequential analysis requires the ALJ to evaluate (1) whether claimant’s work, if any, qualifies as “substantial gainful activity”; (2) whether the claimant’s medically determinable impairments are severe; (3) whether any of the claimant’s impairments “meet or equal the requirements for impairments listed in the regulations”; (4) whether the claimant is able to perform “past relevant work” considering her residual functional capacity; and (5) whether the claimant can adjust to other work considering her residual functional capacity, age, education, and work experience. Hess v. Comm’r of Soc. Sec., 931 F.3d 198, 201-202 (3d Cir. 2019) (citing 20 C.F.R. § 416.920(a)(4)(i)- (v)). The claimant has the burden of proof at steps one through four, and then at step five, the burden shifts to the Commissioner of Social Security. Id. at 201. regulations. R.27-29 (considering Listings 12.04, 12.06, 12.11, and 12.15). In doing so, the ALJ considered whether the “paragraph B” criteria were satisfied, which requires evidence establishing that Plaintiff’s mental impairments result in one “extreme” limitation or two “marked” limitations in a broad area of functioning. R.27. Specifically, the ALJ concluded that Plaintiff had only

“moderate” limitations in each of the four areas: (1) understanding, remembering, or applying information; (2) interacting with others, (3) concentrating, persisting, or maintaining pace; and (4) adapting or managing oneself. R.27-29. As relevant to the instant appeal, the ALJ acknowledged that Plaintiff had memory issues. During her consultative examination, Plaintiff had difficulty recalling details about her past history, and she struggled to recall objects after a delay. R.27-28.

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SPEAKS v. COMMISSIONER OF SOCIAL SECURITY, Counsel Stack Legal Research, https://law.counselstack.com/opinion/speaks-v-commissioner-of-social-security-paed-2025.