Spence v. Dudek

CourtDistrict Court, S.D. West Virginia
DecidedMarch 27, 2025
Docket3:24-cv-00561
StatusUnknown

This text of Spence v. Dudek (Spence 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
Spence v. Dudek, (S.D.W. Va. 2025).

Opinion

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

HUNTINGTON DIVISION PRISCILLA S., Plaintiff, vs. CIVIL ACTION NO. 3:24-CV-00561 LELAND DUDEK, ACTING COMMISSIONER OF SOCIAL SECURITY,

Defendant. PROPOSED FINDINGS AND RECOMMENDATION This is an action seeking review of the final decision of the Acting Commissioner of Social Security (hereinafter “Commissioner”) denying the Plaintiff’s application for Disability Insurance Benefits (DIB) under Title II of the Social Security Act, 42 U.S.C. §§ 401-433. By Order entered October 10, 2024 (ECF No. 3), this case was referred to the undersigned United States Magistrate Judge to consider the pleadings and evidence, and to submit proposed findings of fact and recommendations for disposition pursuant to 28 U.S.C. § 636(b)(1)(B). Presently pending before the Court are the Plaintiff’s Brief in support of her complaint (ECF No. 10) and the Commissioner’s Brief in Support of Defendant’s Decision (ECF No. 11). Having fully considered the record and the arguments of the parties, the undersigned respectfully RECOMMENDS that the United States District Judge GRANT the Plaintiff’s request for remand (ECF No. 10), DENY the Defendant’s request to affirm the final decision (ECF No. 11); REVERSE the final decision of the Commissioner; and REMAND this matter back to the Acting Commissioner pursuant to the fourth sentence of 42 U.S.C. § 405(g) for further administrative proceedings for the reasons stated infra:

1 Procedural History The Plaintiff protectively filed her application for DIB on April 3, 2021 alleging disability beginning May 17, 2021 because of TMJ, cirrhosis, arthritis, migraines, gastroparesis, “palanotal abscesses”, GERD, fibromyalgia, osteoarthritis, asthma, hypothyroidism, depression, anxiety,

esophageal issues, hot flashes, night sweats, high blood pressure, high cholesterol, overactive bladder, “broken pelvis in two places”, “broken tailbone three times”, two bulging discs in lower back, nerve issues in back, swelling in ankles and feet, lumbar back pain, cornea damage from dry eye, and the beginnings of cataracts. (Tr. at 17, 227) Her claim was initially denied on January 13, 2022 (Tr. at 17, 73-81) and again upon reconsideration on March 13, 2023 (Tr. at 17, 83-91). Thereafter, she filed a written request for hearing on April 22, 2023 (Tr. at 114-115). An administrative hearing was held on February 6, 2024 before the Honorable Joanna Papazekos, Administrative Law Judge (“ALJ”). (Tr. at 40-71) On April 24, 2024, the ALJ entered an unfavorable decision. (Tr. at 14-39) On April 24, and May 8, 2024, the Plaintiff sought review by the Appeals Council of the ALJ’s decision. (Tr. at 186-188, 189-191) The ALJ’s decision

became the final decision of the Commissioner on August 15, 2024 when the Appeals Council denied the Plaintiff’s Request for Review. (Tr. at 1-6) On May 7, 2023, the Plaintiff timely brought the present action seeking judicial review of the administrative decision pursuant to 42 U.S.C. § 405(g). (ECF No. 1) The Commissioner filed a Transcript of the Administrative Proceedings. (ECF No. 7) Subsequently, the Plaintiff filed her Brief in support her complaint (ECF No. 10), and in response, the Commissioner filed a Brief in Support of Defendant’s Decision (ECF No. 11); finally, the Plaintiff filed her Reply Brief (ECF No. 12). Consequently, this matter is fully briefed and ready for resolution.

2 The Plaintiff’s Background The record shows that the Plaintiff was 57 years old as of the alleged onset date, therefore defined as a “person of advanced age” during the underlying proceedings. See 20 C.F.R. § 404.1563(e). (Tr. at 60) She has a bachelor’s degree in art education, and last worked as an economic service worker, taking applications for SNAP benefits, as an early head start educator,

and received a subsidy for caring for her disabled adult daughter (Tr. at 32, 47-49). Standard Under 42 U.S.C. § 423(d)(5) and § 1382c(a)(3)(H)(i), a claimant for disability benefits has the burden of proving a disability. See Blalock v. Richardson, 483 F.2d 773, 774 (4th Cir. 1972). A disability is defined as the “inability to engage in any substantial gainful activity by reason of any medically determinable impairment which can be expected to last for a continuous period of not less than 12 months . . . .” 42 U.S.C. § 423(d)(1)(A). The Social Security Regulations establish a “sequential evaluation” for the adjudication of disability claims. 20 C.F.R. § 404.1520. If an individual is found “not disabled” at any step, further inquiry is unnecessary. Id. § 404.1520(a). The first inquiry under the sequence is whether a claimant is currently engaged in substantial gainful employment. Id. § 404.1520(b). If the claimant is not, the second inquiry is whether claimant suffers from a severe impairment. Id. § 404.1520(c).

If a severe impairment is present, the third inquiry is whether such impairment meets or equals any of the impairments listed in Appendix 1 to Subpart P of the Administrative Regulations No. 4. Id. § 404.1520(d). If it does, the claimant is found disabled and awarded benefits. Id. If it does not, the fourth inquiry is whether the claimant’s impairments prevent the performance of past relevant work. Id. § 404.1520(f). By satisfying inquiry four, the claimant establishes a prima facie case of disability. Hall v. Harris, 658 F.2d 260, 264 (4th Cir. 1981).

3 The burden then shifts to the Commissioner, McLain v. Schweiker, 715 F.2d 866, 868-69 (4th Cir. 1983), and leads to the fifth and final inquiry: whether the claimant is able to perform other forms of substantial gainful activity, considering claimant’s remaining physical and mental capacities and claimant’s age, education and prior work experience. Id. § 404.1520(g). The Commissioner must show two things: (1) that the claimant, considering claimant’s age, education, work experience, skills and physical shortcomings, has the capacity to perform an alternative job, and (2) that this specific job exists in the national economy. McLamore v. Weinberger, 538 F.2d 572, 574 (4th Cir. 1976).

When a claimant alleges a mental impairment, the Social Security Administration (“SSA”) “must follow a special technique at every level in the administrative review process.” 20 C.F.R. § 404.1520a(a).

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