Tammi S.W. v. Commissioner of Social Security

CourtDistrict Court, D. New Jersey
DecidedOctober 24, 2025
Docket1:24-cv-09889
StatusUnknown

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

Bluebook
Tammi S.W. v. Commissioner of Social Security, (D.N.J. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW JERSEY CAMDEN VICINAGE

TAMMI S.W. Plaintiff,

v. Civil No. 1:24-cv-09889 (RMB)

COMMISSIONER OF SOCIAL OPINION SECURITY,

Defendant.

APPEARANCES

Samuel Fishman Chermol & Fishman, LLC 11450 Bustleton Avenue Philadelphia, PA 19116

On behalf of Plaintiff

Catherine Elisabeth Hamilton Special Assistant U.S. Attorney c/o Social Security Administration Office of Program Litigation, Office 3 Office of the General Counsel 6401 Security Boulevard Baltimore, MD 21235

On behalf of Defendant

RENÉE MARIE BUMB, Chief United States District Judge

This matter comes before the Court upon an appeal filed by Plaintiff Tammi S.W. (“Plaintiff”) seeking judicial review of the final determination of the Commissioner of the Social Security Administration (the “SSA”), which denied her application for Social Security Disability benefits. For the reasons set forth herein, the Court AFFIRMS the decision of the Administrative Law Judge (“ALJ”).

I. PROCEDURAL HISTORY On August 31, 2021, Plaintiff filed an application for Social Security Disability benefits under Title II of the Social Security Act (the “Act”), alleging an onset date of disability beginning March 11, 2021. [R. at 17.] The claim was first denied on January

18, 2022, and again denied upon reconsideration on June 28, 2022. [Id.] Plaintiff filed a timely written request for a hearing before an ALJ. [Id.] That hearing took place on June 28, 2022. [Id.] Plaintiff was represented by an attorney at the hearing at which the ALJ heard testimony from Plaintiff. [Id.] The ALJ also heard testimony from a vocational expert, Cherie Plante. [Id.] The ALJ issued her decision

on February 6, 2024, finding that Plaintiff was not disabled under the Act. [See infra at III.B.] On August 22, 2024, the Appeals Council denied Plaintiff’s renewed request for review, rendering the ALJ’s decision final. [R. at 1-3.] Plaintiff now seeks this Court’s review pursuant to 42 U.S.C. § 405(g). II. STANDARD OF REVIEW

When reviewing a final decision of an ALJ with regard to disability benefits, a court must uphold the ALJ’s factual decisions if they are supported by “substantial evidence.” Knepp v. Apfel, 204 F.3d 78, 83 (3d Cir. 2000); 42 U.S.C. §§ 405(g), 1383(c)(3). “Substantial evidence” means “‘more than a mere scintilla. It 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) (quoting Cons. Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)); Plummer v. Apfel, 186 F.3d 422, 427 (3d Cir. 1999).

In addition to the “substantial evidence” inquiry, the court must also determine whether the ALJ applied the correct legal standards. See Friedberg v. Schweiker, 721 F.2d 445, 447 (3d Cir. 1983); Sykes v. Apfel, 228 F.3d 259, 262 (3d Cir. 2000). The Court’s review of legal issues is plenary. Sykes, 228 F.3d at 262 (citing Schaudeck v. Comm’r of

Soc. Sec., 181 F.3d 429, 431 (3d Cir. 1999)). The Social Security Act defines “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 twelve months.” 42 U.S.C. §

1382c(a)(3)(A). The Act further states, [A]n individual shall be determined to be under a disability only if his physical or mental impairment or impairments are of such severity that he is not only unable to do his previous work but cannot, considering his age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy, regardless of whether such work exists in the immediate area in which he lives, or whether a specific job vacancy exists for him, or whether he would be hired if he applied for work.

42 U.S.C. § 1382c(a)(3)(B).

The Commissioner has promulgated a five-step, sequential analysis for evaluating a claimant’s disability, as outlined in 20 C.F.R. § 404.1520(a)(4)(i–v). The analysis proceeds as follows: At step one, the ALJ determines whether the claimant is performing “substantial gainful activity[.]” 20 C.F.R. §§ 404.1520(a)(4)(i), 416.920(a)(4)(i). If he is, he is not disabled. Id. Otherwise, the ALJ moves on to step two.

At step two, the ALJ considers whether the claimant has any “severe medically determinable physical or mental impairment” that meets certain regulatory requirements. Id. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). A “severe impairment” is one that “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” Id. §§ 404.1520(c), 416.920(c). If the claimant lacks such an impairment, he is not disabled. Id. §§ 404.1520(a)(4)(ii), 416.920(a)(4)(ii). If he has such an impairment, the ALJ moves on to step three.

At step three, the ALJ decides “whether the claimant’s impairments meet or equal the requirements of an impairment listed in the regulations.” [Smith v. Comm’r of Soc. Sec., 631 F.3d 632, 634 (3d Cir. 2010)]. If the claimant’s impairments do, he is disabled. 20 C.F.R. §§ 404.1520(a)(4)(iii), 416.920(a)(4)(iii). If they do not, the ALJ moves on to step four.

At step four, the ALJ assesses the claimant’s “residual functional capacity” (“RFC”) and whether he can perform his “past relevant work.” Id. §§ 404.1520(a)(4)(iv), 416.920(a)(4)(iv). A claimant’s “[RFC] is the most [he] can still do despite [his] limitations.” Id. §§ 404.1545(a)(1), 416.945(a)(1). If the claimant can perform his past relevant work despite his limitations, he is not disabled. Id. §§ 404.1520(a)(4)(iv), 416.920(a)(4)(iv). If he cannot, the ALJ moves on to step five.

At step five, the ALJ examines whether the claimant “can make an adjustment to other work[,]” considering his “[RFC,] ... age, education, and work experience.” Id. §§ 404.1520(a)(4)(v), 416.920(a)(4)(v). That examination typically involves “one or more hypothetical questions posed by the ALJ to [a] vocational expert.” Podedworny v. Harris, 745 F.2d 210, 218 (3d Cir. 1984). If the claimant can make an adjustment to other work, he is not disabled. 20 C.F.R. §§ 404.1520(a)(4)(v), 416.920(a)(4)(v). If he cannot, he is disabled.

Hess v. Comm’r of Soc. Sec., 931 F.3d 198 201–02 (3d Cir. 2019) (some alterations omitted). III.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Sullivan v. Zebley
493 U.S. 521 (Supreme Court, 1990)
Diehl v. Barnhart
357 F. Supp. 2d 804 (E.D. Pennsylvania, 2005)
Knepp v. Comm Social Security
204 F.3d 78 (Third Circuit, 2000)
Russell Hess, III v. Commissioner Social Security
931 F.3d 198 (Third Circuit, 2019)
Smith v. Commissioner of Social Security
631 F.3d 632 (Third Circuit, 2010)
Garrett v. Commissioner of Social Security
274 F. App'x 159 (Third Circuit, 2008)
Holley v. Colvin
975 F. Supp. 2d 467 (D. New Jersey, 2013)
Podedworny v. Harris
745 F.2d 210 (Third Circuit, 1984)

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Tammi S.W. v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/tammi-sw-v-commissioner-of-social-security-njd-2025.