Vann v. Dudek

CourtDistrict Court, E.D. North Carolina
DecidedFebruary 10, 2025
Docket7:23-cv-01471
StatusUnknown

This text of Vann v. Dudek (Vann v. Dudek) is published on Counsel Stack Legal Research, covering District Court, E.D. North Carolina primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Vann v. Dudek, (E.D.N.C. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF NORTH CAROLINA SOUTHERN DIVISION No. 7:23-CV-01471-D-BM

MICHELLE VANN, ) ) Plaintiff, ) ) v. ) MEMORANDUM AND ) RECOMMENDATION MICHELLE A. KING, ) Acting Commissioner of Social Security, ) ) Defendant. )

Plaintiff Michelle Vann (“Plaintiff” or, in context, “Claimant”) filed this action pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3) seeking judicial review of the denial of her application for a period of disability, disability insurance benefits (“DIB”), and supplemental security income (“SSI”). This matter is before the court on Plaintiff’s brief [DE-10] (“Pl.’s Brief”) seeking judgment in her favor, Defendant’s brief [DE-12] in opposition (“Def.’s Brief”), and Plaintiff’s reply brief [DE-13] (“Pl.’s Reply”). The parties have fully briefed this matter pursuant to the Supplemental Rules for Social Security Actions under 42 U.S.C. § 405(g), and this case is ripe for adjudication. The briefs were referred to the undersigned magistrate judge for a memorandum and recommendation pursuant to 28 U.S.C. § 636(b)(1). Having reviewed and considered the record, the administrative transcript, the briefs submitted by the parties, and the applicable law, it is recommended that Plaintiff’s brief [DE-10] be denied, Defendant’s brief [DE-12] be allowed, and the final decision of the Commissioner be upheld. I. STATEMENT OF THE CASE Plaintiff protectively filed an application for a period of disability, DIB, and SSI on March 3, 2021, alleging disability beginning November 1, 2020. Transcript of Proceedings (“Tr.”) 98, 243-51. Her claim was denied initially. Tr. 75-98, 145-54. Plaintiff filed a request for reconsideration (Tr. 155), and was denied upon reconsideration on June 13, 2022 (Tr. 99-138). On July 13, 2022, Plaintiff requested a hearing before the Administrative Law Judge (“ALJ”). Tr. 169- 70. A hearing before the ALJ was held on January 23, 2023, at which Plaintiff, represented by

counsel, and a vocational expert (“VE”) appeared and testified. Tr. 41-74. On April 12, 2023, the ALJ issued a decision denying Plaintiff’s request for benefits. Tr. 14-40. On April 21, 2024, Plaintiff requested a review of the ALJ’s decision by the Appeals Council. Tr. 237-39. On September 5, 2023, the Appeals Council denied Plaintiff’s request for review. Tr. 1-6. Plaintiff then filed a complaint in this court seeking review of the now-final administrative decision. II. STANDARD OF REVIEW The scope of judicial review of a final agency decision regarding disability benefits under the Social Security Act (“Act”), 42 U.S.C. § 301 et seq., is limited to determining whether substantial evidence supports the Commissioner’s factual findings and whether the decision was

reached through the application of the correct legal standards. See Coffman v. Bowen, 829 F.2d 514, 517 (4th Cir. 1987). “The findings of the Commissioner . . . as to any fact, if supported by substantial evidence, shall be conclusive . . . .” 42 U.S.C. § 405(g). Substantial evidence is “evidence which a reasoning mind would accept as sufficient to support a particular conclusion.” Laws v. Celebrezze, 368 F.2d 640, 642 (4th Cir. 1966). While substantial evidence is not a “large or considerable amount of evidence,” Pierce v. Underwood, 487 U.S. 552, 565 (1988), it is “more than a mere scintilla . . . and somewhat less than a preponderance.” Laws, 368 F.2d at 642. “In reviewing for substantial evidence, [the court should not] undertake to re-weigh conflicting evidence, make credibility determinations, or substitute [its] judgment for that of the 2 [Commissioner].” Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001) (quoting Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996), superseded by regulation on other grounds, 20 C.F.R. § 416.927(d)(2)). Rather, in conducting the “substantial evidence” inquiry, the court’s review is limited to whether the ALJ analyzed the relevant evidence and sufficiently explained his or her

findings and rationale in crediting the evidence. Sterling Smokeless Coal Co. v. Akers, 131 F.3d 438, 439-40 (4th Cir. 1997). “Judicial review of an administrative decision is impossible without an adequate explanation of that decision by the administrator.” DeLoatche v. Heckler, 715 F.2d 148, 150 (4th Cir. 1983). Where the Appeals Council considers additional evidence before denying the claimant’s request for review of the ALJ’s decision, “the court must ‘review the record as a whole, including the [additional] evidence, in order to determine whether substantial evidence supports the Secretary’s findings.’” Felts v. Astrue, No. 1:11-CV-00054, 2012 WL 1836280, at *1 (W.D. Va. May 19, 2012) (quoting Wilkins v. Sec’y, Dep’t of Health & Hum. Servs., 953 F.2d 93, 96 (4th Cir. 1991)). Remand is required if the court concludes that the Commissioner’s decision is not

supported by substantial evidence based on the record as supplemented by the evidence submitted at the Appeals Council level. Id. at *1-2. III. DISABILITY EVALUATION PROCESS The disability determination is based on a five-step sequential evaluation process as set forth in 20 C.F.R. §§ 404.1520 and 416.920 under which the ALJ is to evaluate a claim: The claimant (1) must not be engaged in “substantial gainful activity [“SGA”],” i.e., currently working; and (2) must have a “severe” impairment that (3) meets or exceeds [in severity] the “listings” of specified impairments, or is otherwise incapacitating to the extent that the claimant does not possess the residual functional capacity [“RFC”] to (4) perform . . . past work or (5) any other work.

Albright v. Comm’r of the Soc. Sec. Admin., 174 F.3d 473, 475 n.2 (4th Cir. 1999). “If an 3 applicant’s claim fails at any step of the process, the ALJ need not advance to the subsequent steps.” Pass v. Chater, 65 F.3d 1200, 1203 (4th Cir. 1995) (citation omitted).

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Related

Pierce v. Underwood
487 U.S. 552 (Supreme Court, 1988)
Winschel v. Commissioner of Social Security
631 F.3d 1176 (Eleventh Circuit, 2011)
Bonnilyn Mascio v. Carolyn Colvin
780 F.3d 632 (Fourth Circuit, 2015)
Grayson O Company v. Agadir International LLC
856 F.3d 307 (Fourth Circuit, 2017)
Coffman v. Bowen
829 F.2d 514 (Fourth Circuit, 1987)

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Bluebook (online)
Vann v. Dudek, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vann-v-dudek-nced-2025.