Watson v. Kijakazi

CourtDistrict Court, S.D. New York
DecidedApril 29, 2024
Docket1:23-cv-03143
StatusUnknown

This text of Watson v. Kijakazi (Watson v. Kijakazi) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Watson v. Kijakazi, (S.D.N.Y. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ----------------------------------------------------- JULIE W.,

Plaintiff, DECISION AND ORDER 1:23-CV-03143-GRJ v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant. ----------------------------------------------------- GARY R. JONES, United States Magistrate Judge:

In February of 2021, Plaintiff Julie W.1 applied for Disability Insurance Benefits under the Social Security Act. The Commissioner of Social Security denied the application. Plaintiff, represented by the Law Office of Joseph A. Romano, Joseph Albert Romano, Esq., of counsel, commenced this action seeking judicial review of the Commissioner’s denial of benefits under 42 U.S.C. §§ 405 (g) and 1383 (c)(3). The parties consented to the jurisdiction of a United States Magistrate Judge. (Docket No. 16). This case was referred to the undersigned on March 7, 2024. Presently pending is Plaintiff’s Motion for Judgment on the Pleadings under Rule 12 (c) of the Federal Rules of Civil Procedure. (Docket No. 12). For

1 Plaintiff’s name has been partially redacted in compliance with Federal Rule of Civil Procedure 5.2 (c)(2)(B) and the recommendation of the Committee on Court Administration and Case Management of the Judicial Conference of the United States. the following reasons, Plaintiff’s motion is due to be denied and this case is dismissed.

I. BACKGROUND A. Administrative Proceedings Plaintiff applied for benefits on February 22, 2021, alleging disability

beginning June 30, 2020. (T at 145, 275).2 Plaintiff’s application was denied initially and on reconsideration. She requested a hearing before an Administrative Law Judge (“ALJ”). A hearing was held on March 8, 2022, before ALJ Mark Solomon. (T at 90-125). Plaintiff appeared with an

attorney and testified. (T at 95-112, 113-119). The ALJ also received testimony from Nancy Gilpatrick, a vocational expert. (T at 120-24). B. ALJ’s Decision

On April 7, 2022, the ALJ issued a decision denying the application for benefits. (T at 48-69). The ALJ found that Plaintiff had not engaged in substantial gainful activity since June 30, 2020 (the alleged onset date) and would meet the insured status requirements of the Social Security Act

through June 30, 2023 (the date last insured). (T at 53). The ALJ concluded that Plaintiff’s lumbar and cervical degenerative disc disease;

2 Citations to “T” refer to the administrative record transcript at Docket No. 10. lumbar radiculopathy; and obesity were severe impairments as defined under the Act. (T at 54).

However, the ALJ found that Plaintiff did not have an impairment or combination of impairments that met or medically equaled one of the listed impairments in 20 CFR Part 403, Subpart P, Appendix 1. (T at 57).

At step four of the sequential analysis the ALJ determined that Plaintiff retained the residual functional capacity (“RFC”) to perform sedentary work, as defined in 20 CFR 404.1567(a), with the following limitations: she can sit for 6 hours and stand/walk for 2 hours during an 8-

hour workday; lift/carry 10 pounds occasionally and 5 pounds frequently; and perform occasional climbing, balancing, stooping, kneeling, crouching, and crawling. (T at 57-58).

The ALJ concluded that Plaintiff could perform her past relevant work as a user support analyst. (T at 64). As such, the ALJ found that Plaintiff had not been under a disability, as defined under the Social Security Act, and was not entitled to benefits

for the period between June 30, 2020 (the alleged onset date) and April 7, 2022 (the date of the ALJ’s decision). (T at 65). On March 8, 2023, the Appeals Council denied Plaintiff’s request for review, making the ALJ’s decision the Commissioner’s final decision. (T at

1-7). C. Procedural History Plaintiff commenced this action, by and through her counsel, by filing

a Complaint on April 14, 2023. (Docket No. 1). On August 15, 2023, Plaintiff filed a motion for judgment on the pleadings, supported by a memorandum of law. (Docket Nos. 12, 13). The Commissioner interposed a brief in opposition to the motion and in support of the denial of benefits,

on September 28, 2023. (Docket No. 17). On October 12, 2023, Plaintiff submitted a reply memorandum of law in further support of her motion. (Docket No. 18).

II. APPLICABLE LAW A. Standard of Review “It is not the function of a reviewing court to decide de novo whether a claimant was disabled.” Melville v. Apfel, 198 F.3d 45, 52 (2d Cir. 1999).

The court’s review is limited to “determin[ing] whether there is substantial evidence supporting the Commissioner's decision and whether the Commissioner applied the correct legal standard.” Poupore v. Astrue, 566

F.3d 303, 305 (2d Cir. 2009) (per curiam). The reviewing court defers to the Commissioner's factual findings, which are considered conclusive if supported by substantial evidence. See

42 U.S.C. § 405(g). “Substantial evidence” is “more than a mere scintilla” and “means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Lamay v. Commissioner of Soc. Sec.,

562 F.3d 503, 507 (2d Cir. 2009) (internal quotations omitted) (quoting Richardson v. Perales, 402 U.S. 389, 401 (1971)). “In determining whether the agency's findings are supported by substantial evidence, the reviewing court is required to examine the entire

record, including contradictory evidence and evidence from which conflicting inferences can be drawn.” Talavera v. Astrue, 697 F.3d 145, 151 (2d Cir. 2012) (internal quotations omitted).

“When there are gaps in the administrative record or the ALJ has applied an improper legal standard,” or when the ALJ’s rationale is unclear, remand “for further development of the evidence” or for an explanation of the ALJ’s reasoning is warranted. Pratts v. Chater, 94 F.3d 34, 39 (2d Cir.

1996). B. Five-Step Sequential Evaluation Process Under the Social Security Act, a claimant is disabled if he or she

lacks the ability “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 which has lasted or can be expected to last

for a continuous period of not less than 12 months ....” 42 U.S.C. § 423(d)(1)(A). A claimant’s eligibility for disability benefits is evaluated pursuant to a

five-step sequential analysis: 1. The Commissioner considers whether the claimant is currently engaged in substantial gainful activity.

2.

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