Staten v. Commissioner of Social Security

CourtDistrict Court, W.D. Virginia
DecidedMarch 17, 2025
Docket4:23-cv-00029
StatusUnknown

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

Bluebook
Staten v. Commissioner of Social Security, (W.D. Va. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT —-*/ u/ 2025 POR THE WESTERN DISTRICT OF VIRGINIA 2c xm DANVILLE DIVISION MICHAEL S., ) Plaintiff, Civil Action No. 4:23-cv-00029 v. MEMORANDUM OPINION COMMISSIONER OF SOCIAL By: Hon. Thomas T. Cullen SECURITY, ) United States District Judge Defendant.

Plaintiff Michael S. (‘Michael’) filed suit in this court seeking review of the Commissioner of Social Security’s (‘Commissioner’) final decision denying his claim for disability insurance benefits (‘DIB’) and supplemental security income (“SSI”) under Titles II and XVI of the Social Security Act, 42 U.S.C. §§ 401-433, 1601-1637. Michael does not challenge the determinations related to his physical impairments; rather, his challenge focuses on alleged failures to appropriately consider his mental limitations. After a hearing, an administrative law judge (“ALJ”) concluded that, despite his limitations, Michael could still perform a range of light work. Michael challenges that conclusion, calling for reversal and remand on two primary grounds. But because the ALJ considered all the evidence in the record and adequately explained her rationale for the conclusions she reached, the Commissioner’s final decision will be affirmed. I. STANDARD OF REVIEW The Social Security Act (the “Act’’) authorizes this court to review the Commissionet’s final decision that a person is not entitled to disability benefits. 42 U.S.C. § 405(g); see also Hines

v. Barnhart, 453 F.3d 559, 561 (4th Cir. 2006). The court’s role, however, is limited; it may not “reweigh conflicting evidence, make credibility determinations, or substitute [its] judgment” for that of agency officials. Hancock v. Astrue, 667 F.3d 470, 472 (4th Cir. 2012) (internal

quotation omitted). Instead, in reviewing the merits of the Commissioner’s final decision, a court asks only whether the ALJ applied the correct legal standards and whether “substantial evidence” supports the ALJ’s factual findings. Meyer v. Astrue, 662 F.3d 700, 704 (4th Cir. 2011); see Riley v. Apfel, 88 F. Supp. 2d 572, 576 (W.D. Va. 2000) (citing Melkonyan v. Sullivan, 501 U.S. 89, 99–100 (1991)). In this context, “substantial evidence” means “such relevant evidence as a reasonable

mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971) (internal quotation omitted). It is “more than a mere scintilla” of evidence, id., but not necessarily “a large or considerable amount of evidence,” Pierce v. Underwood, 487 U.S. 552, 565 (1988). Substantial evidence review considers the entire record, and not just the evidence cited by the ALJ. See Universal Camera Corp. v. NLRB, 340 U.S. 474, 487–89 (1951); Gordon v. Schweiker, 725 F.2d 231, 236 (4th Cir. 1984). Ultimately, this court must affirm the ALJ’s factual

findings if “conflicting evidence allows reasonable minds to differ as to whether a claimant is disabled.” Johnson v. Barnhart, 434 F.3d 650, 653 (4th Cir. 2005) (per curiam) (internal quotation omitted). But “[a] factual finding by the ALJ is not binding if it was reached by means of an improper standard or misapplication of the law.” Coffman v. Bowen, 829 F.2d 514, 517 (4th Cir. 1987). A person is “disabled” within the meaning of the Act if he is unable “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). Social Security ALJs follow a five-step process to determine whether a claimant is disabled. The ALJ

asks, in sequence, whether the claimant: (1) is working; (2) has a severe impairment that satisfies the Act’s duration requirement; (3) has an impairment that meets or equals an impairment listed in the Act’s regulations; (4) can return to his past relevant work (if any) based on his residual functional capacity (“RFC”); and, if not (5) whether he can perform other work. See Heckler v. Campbell, 461 U.S. 458, 460–62 (1983); Lewis v. Berryhill, 858 F.3d 858, 861 (4th Cir. 2017); 20 C.F.R. § 404.1520(a)(4). The claimant bears the burden of proof through step

four. Lewis, 858 F.3d at 861. At step five, the burden shifts to the agency to prove that the claimant is not disabled. See id. II. RELEVANT PROCEDURAL HISTORY AND EVIDENCE Michael filed for DIB and SSI benefits on February 6, 2020. (See R. 18; 226–39.) He claimed a disability onset date of June 1, 2019, resulting from myriad health issues: a stroke suffered on June 19, 2019; “brain stem”; right-leg difficulty; type-2 diabetes; severe high blood

pressure; stints in his heart; high cholesterol; cardio embolic stroke; coronary arteriosclerosis; hyperlipidemia; hypertensive heart disease; paroxysmal atrial fibrillation; myocardial infarction; dysarthria; and bursitis in his right shoulder. (See R. 69.) His claims were denied initially on December 21, 2020 (R. 68–111), and upon reconsideration on January 27, 2022 (R. 116–35). Michael requested a hearing before an ALJ. (R. 165–66.) The ALJ held a hearing on March 14, 2023 (R. 44–67), and issued a written decision denying his claim on April 4, 2023

(R. 18–38). Although the ALJ found that Michael suffered from several severe impairments— “a vascular insult to the brain, diabetes mellitus, obesity, hypertension[,] and coronary artery disease”—she determined that Michael could still perform work at the light level, with additional limitations. (See generally id.) Michael appealed that decision, but the Appeals Council

denied his request for review, making the ALJ’s written decision the final decision of the Commissioner as of September 18, 2023. (See R. 1–3.) A. Legal Framework A claimant’s RFC is his “maximum remaining ability to do sustained work activities in an ordinary work setting” for eight hours a day, five days a week, despite his medical impairments and related symptoms. SSR 96-8p, 1996 WL 374184, at *2 (July 2, 1996)

(emphasis omitted). The ALJ makes the RFC finding between steps three and four of the five- step disability determination. See Patterson v. Comm’r of Soc. Sec. Admin., 846 F.3d 656, 659 (4th Cir. 2017) (citing 20 C.F.R.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Heckler v. Campbell
461 U.S. 458 (Supreme Court, 1983)
Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Meyer v. Astrue
662 F.3d 700 (Fourth Circuit, 2011)
Riley v. Apfel
88 F. Supp. 2d 572 (W.D. Virginia, 2000)
Melkonyan v. Sullivan
501 U.S. 89 (Supreme Court, 1991)
George Monroe v. Carolyn Colvin
826 F.3d 176 (Fourth Circuit, 2016)
Stacy Lewis v. Nancy Berryhill
858 F.3d 858 (Fourth Circuit, 2017)
Brown v. Commissioner Social Security Administration
873 F.3d 251 (Fourth Circuit, 2017)
Billie J. Woods v. Nancy Berryhill
888 F.3d 686 (Fourth Circuit, 2018)
Nikki Thomas v. Nancy Berryhill
916 F.3d 307 (Fourth Circuit, 2019)
Hancock v. Astrue
667 F.3d 470 (Fourth Circuit, 2012)
Garrett v. Commissioner of Social Security
274 F. App'x 159 (Third Circuit, 2008)
Coffman v. Bowen
829 F.2d 514 (Fourth Circuit, 1987)

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Staten v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/staten-v-commissioner-of-social-security-vawd-2025.