VANDEWALKER v. COMMISSIONER OF SOCIAL SECURITY

District Court, D. New Jersey·Decided August 5, 2025·No. 3:23-cv-14338·Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF NEW JERSEY

DONOVAN V.,1

Plaintiff, Case No. 3:23-cv-14338 v. Magistrate Judge Norah McCann King

FRANK BISIGNANO,2 Commissioner of Social Security,

Defendant.

OPINION AND ORDER

This matter comes before the Court pursuant to Section 205(g) of the Social Security Act, as amended, 42 U.S.C. § 405(g), regarding the application of Plaintiff Donovan V. for Disability Insurance Benefits under Title II of the Social Security Act, 42 U.S.C. §§ 401 et seq. Plaintiff appeals from the final decision of the Commissioner of Social Security denying that application. After careful consideration of the entire record, including the entire administrative record, the Court decides this matter pursuant to Rule 78(b) of the Federal Rules of Civil Procedure. For the reasons that follow, the Court the Court reverses the Commissioner’s decision and remands the matter for further proceedings.

1 The Committee on Court Administration and Case Management of the Judicial Conference of the United States has recommended that, due to significant privacy concerns in social security cases, federal courts should refer to plaintiffs in such cases by only their first names and last initials. See also D.N.J. Standing Order 2021-10. 2 Frank Bisignano, the current Commissioner of Social Security, is substituted as Defendant in his official capacity. See Fed. R. Civ. P. 25(d).

1 I. PROCEDURAL HISTORY On October 31, 2019, Plaintiff filed his application for benefits, alleging that he has been disabled since June 27, 2016. R. 135, 150, 316–22. The application was denied initially and upon reconsideration. R. 176–80, 185–87. Plaintiff sought a de novo hearing before an administrative

law judge (“ALJ”). R. 188–89. ALJ John Campbell held a hearing on July 7, 2020, at which Plaintiff, who was represented by counsel, testified, as did a vocational expert. R. 91–122 (“July 2020 hearing”). In a decision dated October 1, 2020, the ALJ concluded that Plaintiff was not disabled within the meaning of the Social Security Act at any time from June 27, 2016, Plaintiff’s alleged disability onset date, through the date of that decision. R. 154–66 (“the 2020 decision”). On August 24, 2022, the Appeals Council granted Plaintiff’s request to review, vacated the 2020 decision, and remanded the case for further proceedings. R. 172–73.3

3 The Appeals Council remanded the case for resolution of the following issue:

The hearing decision does not contain a discussion of the admissibility of untimely submitted evidence. When a claimant or appointed representative informs the agency about or submits evidence less than five business days before the hearing and the Administrative Law Judge finds that the circumstances in 20 CFR 404.935(b) do not apply, the Administrative Law Judge will identify the evidence and explain the reason for not considering it (HALLEX I-2-6-59 C). A hearing was held on July 7, 2020. Evidence relevant to the period at issue, from Ocean Medical Center, dated May 20, 2017 (26 pages) and Ocean Medical Center, dated January 14, 2019 (21 pages), both received into the electronic folder on September 25, 2020, was not admitted into the record. The decision does not contain an explanation for this omission. Rather, the decision states that the claimant submitted or informed the Administrative Law Judge about all written evidence at least five business days before the date of the claimant’s scheduled hearing (Decision, page 1). Upon remand, this evidence should be entered into the record (HALLEX I-2-1-15 and I- 2-1-20).

Upon remand, the Administrative Law Judge will:

• Consider the evidence from Ocean Medical Center, dated May 20, 2017 (26 pages) and Ocean Medical Center, dated January 14, 2019 (21 pages), received into the electronic folder on September 25, 2 Following remand from the Appeals Council, the ALJ held another hearing on December 2, 2022, at which Plaintiff’s counsel appeared and, in light of difficulty communicating with Plaintiff, the ALJ rescheduled the hearing. R. 85–90. At the rescheduled hearing on March 7, 2023, Plaintiff, who was again represented by counsel, again testified, as did a vocational expert.

R. 51–84 (“March 2023 hearing”). In a decision dated April 4, 2023, the ALJ concluded that Plaintiff was not disabled within the meaning of the Social Security Act at any time from June 27, 2016, the alleged disability onset date, through March 31, 2021, the date on which Plaintiff was last insured for benefits. R. 17–45 (“2023 decision”). That decision became the final decision of the Commissioner of Social Security when the Appeals Council declined review on July 14, 2023. R. 1–6. Plaintiff timely filed this appeal pursuant to 42 U.S.C. § 405(g). ECF No. 1. On April 3, 2024, Plaintiff consented to disposition of the matter by a United States Magistrate Judge pursuant to 28 U.S.C. § 636(c) and Rule 73 of the Federal Rules of Civil Procedure. ECF No. 16.4 On that same day, the case was reassigned to the undersigned. ECF No. 17. The matter is ripe for disposition.

2020, and ensure that all exhibits are selected, arranged, and marked, pursuant to HALLEX I-2-1-15 and I-2-1-20.

In compliance with the above, the Administrative Law Judge will offer the claimant an opportunity for a hearing, address the evidence which was submitted with the request for review, take any further action needed to complete the administrative record and issue a new decision.

Id. 4The Commissioner has provided general consent to Magistrate Judge jurisdiction in cases seeking review of the Commissioner’s decision. See Standing Order In re: Social Security Pilot Project (D.N.J. Apr. 2, 2018). 3 II. LEGAL STANDARD A. Standard of Review In reviewing applications for Social Security disability benefits, this Court has the authority to conduct a plenary review of legal issues decided by the ALJ. Knepp v. Apfel, 204

F.3d 78, 83 (3d Cir. 2000). In contrast, the Court reviews the ALJ’s factual findings to determine if they are supported by substantial evidence. Sykes v. Apfel, 228 F.3d 259, 262 (3d Cir. 2000); see also 42 U.S.C. § 405(g). The United States Supreme Court has explained this standard as follows: Under the substantial-evidence standard, a court looks to an existing administrative record and asks whether it contains sufficien[t] evidence to support the agency’s factual determinations. And whatever the meaning of substantial in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence, this Court has said, is more than a mere scintilla. It means – and means only – such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.

Biestek v. Berryhill, 587 U.S. 97, 102–03 (2019) (internal citations and quotation marks omitted); see also Pierce v.

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