Williams v. Kijakazi

CourtDistrict Court, D. Connecticut
DecidedMarch 31, 2025
Docket3:23-cv-01346
StatusUnknown

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

Bluebook
Williams v. Kijakazi, (D. Conn. 2025).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT CHARLES W., ) CASE NO. 3:23-cv-01346 (KAD) Plaintiff, ) ) v. ) ) KILOLO KIJAKAZI, ) MARCH 31, 2025 Commissioner of the Social Security ) Administration,1 ) Defendant. )

MEMORANDUM OF DECISION RE: PLAINTIFF’S MOTION TO REVERSE (ECF NO. 14) AND COMMISSIONER’S MOTION TO AFFIRM (ECF NO. 15)

Kari A. Dooley, United States District Judge: Plaintiff Charles W. (“Plaintiff”) brings this administrative appeal pursuant to 42 U.S.C. § 405(g). He appeals the decision of defendant Leland Dudek, Acting Commissioner of the Social Security Administration (“Commissioner”), denying his application for disability insurance benefits pursuant to Title II of the Social Security Act (the “Act”). Plaintiff moves to reverse the Commissioner’s decision on the ground that the Commissioner’s findings are not supported by substantial evidence in the record. Alternatively, he seeks a remand for further proceedings before the Commissioner, on the ground that he did not receive a full and fair hearing. In response, the Commissioner asserts that the Commissioner’s findings are supported by substantial evidence and moves for an order affirming the Commissioner’s decision. For the reasons set forth below, the Commissioner’s motion to affirm is GRANTED. (ECF No. 15). Plaintiff’s motion to reverse or remand is DENIED. (ECF No. 14).

1 Plaintiff commenced this action on October 16, 2024, against Kilolo Kijakazi, former Commissioner of the Social Security Administration. On February 16, 2025, Leland Dudek became Acting Commissioner of the Social Security Administration. Pursuant to Fed. R. Civ. P. 25(d), Acting Commissioner Dudek is automatically substituted for Kilolo Kijakazi as the named defendant. The Clerk of the Court is requested to amend the caption in this case to reflect same. Standard of Review A person is “disabled” under the Act if that person is unable 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); 1382c(a)(3)(A). A physical or mental impairment is one “that results from anatomical, physiological, or psychological abnormalities which are demonstrable by medically acceptable clinical and laboratory diagnostic techniques.” Id. §§ 423(d)(3); 1382c(a)(3)(D). In addition, a claimant must establish that their physical or mental impairment or impairments are of such severity that they are not only unable to do their previous work but “cannot, considering [their] age, education, and work experience, engage in any other kind of substantial gainful work which exists in the national economy…” Id. §§ 423(d)(2)(A); 1382c(a)(3)(B). Pursuant to regulations promulgated by the Commissioner, a five-step sequential evaluation process is used to determine whether a claimant’s condition meets the Act’s definition

of disability. See 20 C.F.R. §§ 404.1520; 416.920. In brief, the five steps are as follows: (1) the Commissioner determines whether the claimant is currently engaged in substantial gainful activity; (2) if not, the Commissioner determines whether the claimant has “a severe medically determinable physical or mental impairment that meets the duration requirement in §[§] 404.1509; [§ 416.909]” or a combination of impairments that is severe and meets the duration requirements; (3) if such a severe impairment is identified, the Commissioner next determines whether the medical evidence establishes that the claimant’s impairment “meets or equals” an impairment listed in Appendix 1 of the regulations;2 (4) if the claimant does not establish the “meets or equals”

2 Appendix 1 to Subpart P of Part 404 of C.F.R. 20 is the “Listing of Impairments.” requirement, the Commissioner must then determine the claimant’s residual functional capacity (“RFC”) to perform his past relevant work; and (5) if the claimant is unable to perform his past work, the Commissioner must finally determine whether there is other work in the national economy which the claimant can perform in light of their RFC, education, age, and work

experience. Id. §§ 404.1509; 404.1520(a)(4)(i)-(v); 416.909; 416.920(a)(4)(i)–(v). The claimant bears the burden of proof with respect to Steps One through Four and the Commissioner bears the burden of proof at Step Five. See McIntyre v. Colvin, 758 F.3d 146, 150 (2d Cir. 2014); Sczepanski v. Saul, 946 F.3d 152, 158 (2d Cir. 2020). The fourth sentence of § 405(g) of the Act provides that a “court shall have power to enter, upon the pleadings and transcript of the record, a judgment affirming, modifying, or reversing the decision of the Commissioner. . . with or without remanding the case for a rehearing.” 42 U.S.C. § 405(g). And it is well-settled that a district court will reverse the decision of the Commissioner only when it is based upon legal error or when it is not supported by substantial evidence in the record. See Beauvoir v. Chater, 104 F.3d 1432, 1433 (2d Cir. 1997); see also 42 U.S.C. § 405(g)

(“The findings of the Commissioner of Social Security as to any fact, if supported by substantial evidence, shall be conclusive. . .”). “Substantial evidence is more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Talavera v. Astrue, 697 F.3d 145, 151 (2d Cir. 2012) (internal quotations omitted). The court does not inquire as to whether the record might also support the plaintiff’s claims but only whether there is substantial evidence to support the Commissioner’s decision. Bonet ex rel. T.B. v. Colvin, 523 Fed. Appx. 58, 59 (2d Cir. 2013). Thus, substantial evidence can support the Commissioner’s findings even if there is the potential for drawing more than one conclusion from the record. See Vance v. Berryhill, 860 F.3d 1114, 1120 (8th Cir. 2017). The court can only reject the Commissioner’s findings of facts “if a reasonable factfinder would have to conclude otherwise.” Brault v. Social Sec. Admin., 683 F.3d 443, 448 (2d Cir. 2012). Stated simply, “if there is substantial evidence to support the [Commissioner’s] determination, it must be upheld.” Selian v. Astrue, 708 F.3d 409, 417 (2d Cir. 2013).

Facts and Procedural History On March 28, 2012, Plaintiff filed an application for disability insurance benefits3 pursuant to Title II of the Act4 and supplemental security income5 pursuant to Title XVI of the Act,6, alleging a disability onset date of June 25, 2010. (Tr., ECF No. 11, at 469–81). These claims were initially denied on May 18, 2012, (Tr., 226–37), and denied upon reconsideration on March 1, 2013. (Tr. at 258–59, 278–79).

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Related

Brault v. Social Security Administration
683 F.3d 443 (Second Circuit, 2012)
Josephine L. Cage v. Commissioner of Social Security
692 F.3d 118 (Second Circuit, 2012)
Talavera v. Comm’r of Social Security
697 F.3d 145 (Second Circuit, 2012)
Selian v. Astrue
708 F.3d 409 (Second Circuit, 2013)
Bonet Ex Rel. T.B. v. Colvin
523 F. App'x 58 (Second Circuit, 2013)
Santos-Sanchez v. Astrue
723 F. Supp. 2d 630 (S.D. New York, 2010)
Patricia Vance v. Nancy A. Berryhill
860 F.3d 1114 (Eighth Circuit, 2017)
McIntyre v. Colvin
758 F.3d 146 (Second Circuit, 2014)

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Williams v. Kijakazi, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-kijakazi-ctd-2025.