Wall v. Commissioner of Social Security

CourtDistrict Court, M.D. Pennsylvania
DecidedApril 3, 2025
Docket3:23-cv-00850
StatusUnknown

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

Bluebook
Wall v. Commissioner of Social Security, (M.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE MIDDLE DISTRICT OF PENNSYLVANIA

LISA WALL, : Civil No. 3:23-CV-00850 : Plaintiff, : : v. : : LELAND DUDEK,1 : Acting Commissioner of Social Security : (Magistrate Judge Carlson) : Defendant. :

MEMORANDUM OPINION

I. Introduction For Administrative Law Judges (ALJs) Social Security disability decisions often entail an evaluation of the persuasive power of various medical opinions. An ALJ undertakes this task guided by regulations which call upon the ALJ to assess each medical opinion in terms of its consistency and supportability. Once the ALJ has made this decision, on appeal it is the Court’s responsibility to decide whether substantial evidence, fully articulated by the ALJ, supports the

1Leland Dudek became the Acting Commissioner of Social Security on February 16, 2025. Pursuant to Rule 25(d) of the Federal Rules of Civil Procedure, Leland Dudek should be substituted for the previously named defendant in this suit. No further action need be taken to continue this suit by reason of the last sentence of section 205(g) of the Social Security Act, 42 U.S.C. § 405(g).

1 disability determination. This “substantial evidence” test is a highly deferential standard of review. As the Supreme Court has explained:

The phrase “substantial evidence” is a “term of art” used throughout administrative law to describe how courts are to review agency factfinding. T-Mobile South, LLC v. Roswell, 574 U.S. ––––, ––––, 135 S. Ct. 808, 815, 190 L.Ed.2d 679 (2015). 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. Consolidated Edison Co. v. NLRB, 305 U.S. 197, 229, 59 S. Ct. 206, 83 L.Ed. 126 (1938) (emphasis deleted). 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.” Ibid.; see, e.g., Perales, 402 U.S. at 401, 91 S. Ct. 1420 (internal quotation marks omitted). It means—and means only—“such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Consolidated Edison, 305 U.S. at 229, 59 S. Ct. 206. See Dickinson v. Zurko, 527 U.S. 150, 153, 119 S. Ct. 1816, 144 L.Ed.2d 143 (1999) (comparing the substantial-evidence standard to the deferential clearly- erroneous standard). Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019). Under this standard of review, we are obliged to affirm the decision of the administrative law judge (ALJ) once we find that it is “supported by substantial evidence, ‘even [where] this court acting de novo might have reached a different conclusion.’” Monsour Med. Ctr. v. Heckler, 806 F.2d 1185, 1190–91 (3d Cir. 1986) (quoting Hunter Douglas, Inc. v. NLRB, 804 F.2d 808, 812 (3d Cir. 1986)).

2 In the instant case we are called upon to decide whether substantial evidence, which was adequately articulated by the ALJ, supported the conclusion that the

medical opinion of a non-treating consultant, Dr. Sarah Vanes, was less persuasive than two state agency expert opinions. Mindful of the fact that substantial evidence “means only—‘such relevant evidence as a reasonable mind might accept as

adequate to support a conclusion,’” Biestek, 139 S. Ct. at 1154, we conclude that substantial evidence supported the ALJ’s mental medical opinion findings in this case. Therefore, for the reasons set forth below, we will affirm the decision of the Commissioner denying this claim.

II. Statement of Facts and of the Case

A. Background

The administrative record of Wall’s disability application reveals the following essential facts: In August of 2021, Wall applied for disability insurance and supplemental security income benefits pursuant to Titles II and XVI of the Social Security Act, alleging an onset of disability beginning November 16, 2020. (Tr. 29). According to Wall, she was completely disabled due to a number of physical and emotional impairments, including major depressive disorder; posttraumatic stress

3 disorder (PTSD); bipolar disorder; panic disorder; anxiety; and schizoaffective disorder, bipolar type. (Tr. 32).2

Wall was born on June 26, 1978, and was 42 years old on the alleged disability onset date, which defined her as a younger individual under the Commissioner’s regulations. (Tr. 42). She had a limited school education and prior employment as a

resident care aide and an assistant manager. (Tr. 41-42). B. Wall’s Clinical History At the time of the alleged onset of her disability in November 2020, Wall was both incarcerated3 and expecting the birth of a child. Following the birth of her child

and her release from custody, Wall was treated through the Geisinger Health System for anxiety and depression. The records of this treatment revealed several consistent themes. Wall was repeatedly diagnosed as suffering from anxiety and depression.

2 Wall’s disability application also listed a number of physical impairments in addition to these emotional conditions. However, in this appeal Wall focuses exclusively upon the ALJ’s consideration of her emotional impairments. Therefore, we will limit our discussion to these emotional impairments.

3 Wall’s incarceration was related to her prior employment as a resident care aide. According to her treatment records, in January of 2000 Wall was charged with abuse of a care dependent person after she was captured on video throwing food on the ground and then making a care dependent person pick up the discarded food and eat it. (Tr. 737-39, 743-46). Wall pleaded guilty to two misdemeanor charges in December of 2020 and was sentenced to home detention. (Tr. 750).

4 Her depression was consistently described as a moderate recurrent depressive disorder. While treatment notes indicated that Wall occasionally voiced fleeting

thoughts of death and endorsed some suspicious and paranoid ideas, she was not deemed a risk of self-harm. Moreover, Wall often reported improvement in her symptoms when she adhered to her medication regime. Furthermore, the treatment

notes contained numerous references to normal or benign findings describing her as fully oriented, with normal mood, affect, behavior, appearance, speech, judgment and thought content. Shortly after her state conviction and the birth of her child, on January 14,

2021, Wall was seen at Geisinger and was diagnosed with postpartum depression. (Tr. 710-11). At a June 3, 2011, clinical encounter Wall reported worsening depression, which was attributed in part to postpartum depression. (Tr. 699). Her

caregivers reported that her mental status was at baseline and described her condition as a moderate episode of recurrent depressive disorder. (Tr. 703). On December 15, 2021, Dr. Sarah Vanes conducted a consultative examination of Wall as part of the disability determination process. (Tr. 948-54). At

that time Wall reported that she was still on home detention following her state conviction. (Tr. 949). Wall described depression which “comes and goes” but denied any suicidal ideation. (Id.) Wall was cooperative throughout the examination, (Id.)

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