Valarie Vega v. Commissioner of Social Security

CourtDistrict Court, D. New Jersey
DecidedApril 7, 2026
Docket2:23-cv-23203
StatusUnknown

This text of Valarie Vega v. Commissioner of Social Security (Valarie Vega 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
Valarie Vega v. Commissioner of Social Security, (D.N.J. 2026).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

VALARIE VEGA,

Plaintiff,

v. Civil Action No. 23-23203

COMMISSIONER OF SOCIAL SECURITY, OPINION Defendant.

ARLEO, UNITED STATES DISTRICT JUDGE THIS MATTER comes before the Court by way of Plaintiff Valerie Vega’s (“Plaintiff”) request for review of Administrative Law Judge (“ALJ”) Ricardy Damille’s decision regarding Plaintiff’s application for Supplemental Security Income Benefits (“SSI”) pursuant to 42 U.S.C. §§ 1383(c)(3), 423, and 405(g). See ECF No. 1. For the reasons set forth in this Opinion, the Commissioner of Social Security’s (the “Commissioner”) decision is AFFIRMED. I. STANDARD OF REVIEW AND APPLICABLE LAW A. Standard of Review This Court has jurisdiction to review the Commissioner’s decision under 42 U.S.C. § 405(g). The Commissioner’s application of the law is subject to plenary review. See Markle v. Barnhart, 324 F.3d 182, 187 (3d Cir. 2003). The Commissioner’s factual findings, however, are binding upon this Court if they are supported by “substantial evidence” in the administrative record. See Knepp v. Apfel, 204 F.3d 78, 83 (3d Cir. 2000). Substantial evidence is defined as “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 Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229 (1938)). Stated differently, substantial evidence consists of “more than a mere scintilla of evidence but may be less than a preponderance.” McCrea v. Comm’r of Soc. Sec., 370 F.3d 357, 360 (3d Cir. 2004). It is a deferential standard of review that prohibits the Court from “weigh[ing] the evidence or substitut[ing] its conclusions for those of the fact-finder.” Williams v. Sullivan, 970 F.2d 1178, 1182 (3d Cir. 1992); see also Stockett v. Comm’r of Soc. Sec., 216 F.

Supp. 3d 440, 453 (D.N.J. 2016) (explaining that the court “must uphold” factual findings based on substantial evidence, “even if the court would have decided the inquiry differently” in the first instance (quotation marks omitted)). In determining whether there is substantial evidence to support the Commissioner’s decision, the Court must consider: “(1) the objective medical facts; (2) the diagnoses of expert opinions of treating and examining physicians on subsidiary questions of fact; (3) subjective evidence of pain testified to by the Plaintiff and corroborated by family and neighbors; and (4) the Plaintiff’s educational background, work history, and present age.” Holley v. Colvin, 975 F. Supp. 2d 467, 475 (D.N.J. 2013), aff’d 590 F. App’x 167 (3d Cir. 2014). The ALJ’s analysis of the evidentiary record is sufficient so long as it “permit[s] [for] meaningful review.” Jones v. Barnhart,

364 F.3d 501, 505 (3d Cir. 2004). Accordingly, the ALJ does not need to have discussed “every tidbit of evidence included in the record,” Hur v. Barnhart, 94 F. App’x 130, 133 (3d Cir. 2004), but he must have “consider[ed] all pertinent medical and non-medical evidence and ‘explain[ed] [any] conciliations and rejections’” of that evidence, Stockett, 216 F. Supp. 3d at 454 (citing Burnett v. Comm’r of Soc. Sec., 220 F.3d 112, 122 (3d Cir. 2000)). B. The Five-Step Disability Test The Social Security Act (“the 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 has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. § 416(i)(1). To determine whether a claimant is disabled under the Act, the Commissioner applies a five-step test. See 20 C.F.R. § 416.920. The claimant bears the burden of proof at steps one through four. See Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987). The burden shifts to the Commissioner at step five. See id. At step one, the Commissioner must determine whether the claimant is engaged in

“substantial gainful activity.” 20 C.F.R. § 416.920(a)(4)(i); 20 C.F.R. § 416.920(b). Substantial gainful activity involves significant mental or physical activities that are “usually done for pay or profit, whether or not a profit is realized.” 20 C.F.R. § 416.972. If the claimant is engaged in such activity, they are not “disabled” under the Act and the benefits are denied. Bowen, 482 U.S. at 140. If the claimant is not engaged in such activity, the Commissioner must proceed to step two and determine whether the claimed impairment—or combination of impairments—is “severe.” 20 C.F.R. § 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.” 20 C.F.R. § 416.920(c). The claimant’s severe impairment must also last or be expected to last “for a continuous period of at least 12 months.” 20 C.F.R. § 404.1505. If the claimant does not have a medically determinable severe

impairment, the benefits are denied. See Bowen, 482 U.S. at 141. At the third step, the Commissioner must determine whether the claimant’s condition is equivalent to a medical impairment enumerated in 20 CFR Part 404, Subpart P, Appendix 1 (“Appendix 1”). See 20 C.F.R. § 416.920(a)(4)(iii); 20 C.F.R. § 416.920(d). If the condition meets or equals one of the listed impairments, “the claimant is conclusively presumed to be disabled.” Bowen, 482 U.S. at 141. If not, the Commissioner proceeds to step four. See id.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
Shirley McCrea v. Commissioner of Social Security
370 F.3d 357 (Third Circuit, 2004)
Anita Holley v. Commissioner Social Security
590 F. App'x 167 (Third Circuit, 2014)
Knepp v. Comm Social Security
204 F.3d 78 (Third Circuit, 2000)
Albury v. Commissioner of Social Security
116 F. App'x 328 (Third Circuit, 2004)
Hur v. Comm Social Security
94 F. App'x 130 (Third Circuit, 2004)
Salles v. Commissioner of Social Security
229 F. App'x 140 (Third Circuit, 2007)
Russell Hess, III v. Commissioner Social Security
931 F.3d 198 (Third Circuit, 2019)
Stockett v. Commissioner of Social Security
216 F. Supp. 3d 440 (D. New Jersey, 2016)
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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Valarie Vega v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/valarie-vega-v-commissioner-of-social-security-njd-2026.