Narcisa P. v. Commissioner of Social Security
- Jones
- 1:23-cv-10962
- U.S. District Court · Southern District of New York
- 12
In Narcisa P. v. Commissioner of Social Security, Judge Jones denied Narcisa P.’s motion for judgment on the pleadings and dismissed the case after upholding the agency’s decision.
Narcisa P., whose application for Disability Insurance Benefits remained denied; the Commissioner of Social Security prevailed, and the case was dismissed.
What happened
Narcisa P. applied for Disability Insurance Benefits, alleging that she became unable to work on April 13, 2020. An Administrative Law Judge found that she had serious neck and back conditions and obesity, but concluded that she could perform some light work and that other jobs existed in significant numbers. The Appeals Council declined to review that decision.
Narcisa P. asked the federal court to overturn the decision, arguing that the finding about her ability to stand and walk was not supported by enough evidence. The court rejected that argument. It explained that moderate limits can be consistent with light work and noted that medical reviewers, treatment records, and her reported daily activities supported the Administrative Law Judge’s conclusion.
Judge Gary R. Jones denied Narcisa P.’s motion for judgment on the pleadings and dismissed the case. The clerk was directed to enter final judgment for the Commissioner of Social Security and close the case.
The detailed version
- Narcisa P. v. Commissioner of Social Security · No. 1:23-cv-10962
- Jones
- Mar. 3, 2025
Background
Narcisa P. applied for Disability Insurance Benefits under the Social Security Act on October 11,
- She alleged disability beginning April 13,
- The Social Security Administration denied the application initially and on reconsideration. After a hearing at which Narcisa P. testified with an attorney and a vocational expert also testified, Administrative Law Judge Kiernan McCormack denied the application on December 1,
- The Appeals Council denied review on October 24, 2023, making the Administrative Law Judge’s decision the Commissioner’s final decision.
The Administrative Law Judge found that Narcisa P.’s cervical disc herniations, lumbar disc herniation with fusion, and obesity were severe impairments. The judge determined that she had the residual functional capacity—the most she could still do in a work setting—to perform light work, with only occasional climbing and stooping. She could not return to her past work as a home health aide, but the judge found that other jobs existed in significant numbers in the national economy. The judge therefore concluded that she was not disabled from April 13, 2020, through December 1, 2022.
Issue and Arguments
Narcisa P. sought judicial review under 42 U.S.C. §§ 405(g) and 1383(c)(3). She moved for judgment on the pleadings, arguing that the residual-functional-capacity finding was not supported by substantial evidence. In particular, she argued that the finding that she could meet the standing and walking requirements of light work conflicted with consulting examiner Dr. Michael Healy’s opinion that she had moderate limitations in standing, walking, bending, lifting, and climbing stairs.
The Commissioner opposed Narcisa P.’s motion and requested judgment on the pleadings in the Commissioner’s favor.
Court’s Analysis
The court reviewed whether substantial evidence supported the Commissioner’s decision and whether the correct legal standard was used. Substantial evidence means relevant evidence that a reasonable person could accept as adequate to support a conclusion. The court explained that it could not decide independently whether Narcisa P. was disabled and had to defer to the Commissioner’s factual findings when supported by substantial evidence.
The court rejected Narcisa P.’s challenge for three reasons. First, it noted that courts have found moderate limitations in standing, walking, sitting, and lifting consistent with the ability to perform light work. Second, the residual-functional-capacity finding was supported by the opinions of two State Agency reviewing physicians. Dr. A. Saeed opined that Narcisa P. could perform light work, and Dr. J. Randall opined that she could perform light work with occasional climbing and stooping. The Administrative Law Judge found these opinions persuasive, as well as Dr. Healy’s opinion.
Third, the court determined that the Administrative Law Judge reasonably read the record as showing that Narcisa P. did not have disabling physical limitations. The record included treatment notes describing a normal gait, full range of motion, and no joint tenderness or swelling, along with evidence that she could perform household chores, use public transportation, and shop. The court acknowledged that she experienced pain and limitations but concluded that the Administrative Law Judge reasonably accounted for them by finding that she could not perform her past work and limiting her to a reduced range of light work.
Disposition
Judge Gary R. Jones held that the Administrative Law Judge’s residual-functional-capacity finding was supported by a reasonable reading of the record and appropriate consideration of the medical opinions. The court denied Narcisa P.’s Motion for Judgment on the Pleadings, dismissed the case, directed the clerk to enter final judgment in favor of the Commissioner, and directed the clerk to close the file.
Read the full 12-page opinion on CourtListener, the free public archive maintained by the Free Law Project.