Velez v. Commissioner of Social Security

CourtDistrict Court, E.D. Virginia
DecidedAugust 18, 2022
Docket3:21-cv-00295
StatusUnknown

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

Bluebook
Velez v. Commissioner of Social Security, (E.D. Va. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF VIRGINIA Richmond Division Candido V.,! Plaintiff, V. Civil Action No. 3:21-cv-295 KILOLO KIJAKAZI,? Acting Commissioner of Social Security, Defendant. OPINION The plaintiff, Candido V., challenges the Social Security Administration (“SSA”) Commissioner’s final decision denying his claim for supplemental security income, a period of disability, and disability insurance benefits. On July 1, 2022, the Magistrate Judge issued a Report and Recommendation (“R&R”) on the parties’ cross-motions for summary judgment. The R&R recommends that the Court (1) deny the plaintiff's motion for summary judgment; (2) grant the SSA Commissioner’s (“the Commissioner”) motion for summary judgment; and (3) affirm the Commissioner’s decision. The plaintiff objects to the R&R for two reasons: (1) because the R&R finds that Nurse Practitioner Gray H. Smith’s note does not amount to a medical opinion prompting articulative duties by the Administrative Law Judge (“ALJ”) such that the ALJ’s failure to address the nurse’s note does not require remand and (2) because the R&R finds that the ALJ did not err when failing

' The Committee on Court Administration and Case Management of the Judicial Conference of the United States recommends that, due to significant privacy concerns in social security cases, federal courts refer to a claimant only by their first name and last initial. 2 On July 9, 2021, Kilolo Kijakazi became the Acting Commissioner of the Social Security Administration. Pursuant to Federal Rule of Civil Procedure 25(d), the Court substitutes Acting Commissioner Kijakazi as the defendant in this suit.

to address whether the plaintiff's impairments met or equaled Listing 1.04A of 20 C.F.R. Part 404, Subpart P, Appendix 1. Because the ALJ applied the correct legal standard and substantial evidence supports his factual findings, the Court will adopt the R&R and overrule the plaintiff's objection. I. BACKGROUND SSA initially denied the plaintiff's claim for supplemental security income, a period of disability, and disability insurance benefits. Upon reconsideration, the SSA denied the plaintiff's claim again. The plaintiff then filed a written request for a hearing before an ALJ. Following the hearing, the ALJ issued a written opinion denying the plaintiff? s claim; in his December 3, 2020 Opinion, the ALJ concluded that the plaintiff was not disabled linder the Social Security Act. The SSA Appeals Council denied the plaintiffs request for review, rendering the ALJ’s decision the final decision of the Commissioner, subject to this Court’s review. On May 7, 2021, the plaintiff filed a complaint in this Court, appealing the Commissioner’s decision pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3). (ECF No. 1.) The Court referred the matter to a magistrate judge for an R&R pursuant to 28 U.S.C. § 636(b)(1)(B), and the parties filed cross-motions for summary judgment. Upon review, the Magistrate Judge recommended that the Court (1) deny the plaintiffs motion for summary judgment; (2) grant the Commissioner’s motion for summary judgment; and (3) affirm the final decision of the Commissioner. (ECF No. 26.) The plaintiff objects to this R&R. II. DISCUSSION This Court reviews de novo any part of the R&R to which a party has properly objected. 28 U.S.C. § 636(b)(1)(C); Fed. R. Civ. P. 72(b)(3). The Court may accept, reject, or modify, in whole or in part, a magistrate judge’s recommended disposition. 28 U.S.C. § 636(b)(1)(C); Fed.

R. Civ. P. 72(b)(3). A court “will affirm the Social Security Administration’s disability determination ‘when an ALJ has applied correct legal standards and the ALJ’s factual findings are supported by substantial evidence.’” Mascio v. Colvin, 780 F.3d 632, 634 (4th Cir. 2015) (quoting Bird v. Comm’r of Soc. Sec. Admin., 699 F.3d 337, 340 (4th Cir. 2012)); see also Craig v. Chater, 76 F.3d 585, 589 (4th Cir. 1996) (clarifying that the question is not whether the claimant is disabled, but whether substantial evidence supports the ALJ’s finding of no disability). Substantial evidence exists to support a finding when there is “relevant evidence [that] a reasonable mind might accept as adequate to support a conclusion.” Johnson v. Barnhart, 434 F.3d 650, 653 (4th Cir. 2005) (quoting Craig, 76 F.3d at 589). In other words, substantial evidence requires more than a scintilla, but less than a preponderance of the evidence. Mastro v. Apfel, 270 F.3d 171, 176 (4th Cir. 2001) (quoting Laws v. Celebrezze, 368 F.2d 640, 642 (4th Cir. 1966)). If “conflicting evidence allows reasonable minds to differ as to whether a claimant is disabled,” the Court must defer to the Commissioner’s decision. Johnson, 434 F.3d at 653. At the same time, the Court “must not abdicate . . . [its] duty to scrutinize the record as a whole to determine whether the conclusions reached are rational.” Oppenheim v, Finch, 495 F.2d 396, 397 (4th Cir. 1974). The ALJ applies a five-step process to determine whether the individual is disabled. 20 C.F.R. §§ 404.1520(a), 416.920(a); see Mascio, 780 F.3d at 634-35 (describing the five-step process). As relevant to the plaintiff's objections here, step three requires the ALJ to determine whether the claimant’s medical impairments meet or equal an impairment listed in the regulations. 20 C.F.R. §§ 404.1520(a)(4)(iii), 416.925(a). And between the third and fourth steps of the analysis, the ALJ must assess and make a finding about the claimant’s residual functional capacity (“RFC”). 20 C.F.R. §§ 416.1545(a), 416.945(a). The RFC is an ALJ’s assessment—based on all

relevant medical and other evidence—of “the most [the claimant] can still do despite [the claimant’s] limitations.” 20 C.F.R. § 416.945(a)(1). The plaintiff objects to the R&R on two grounds.

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Velez v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/velez-v-commissioner-of-social-security-vaed-2022.