Manglik v. Commissioner of Social Security
2:24-cv-00025
E.D.N.C.Jun 2, 2025Background
- Amit Manglik filed a claim for Social Security Disability Insurance Benefits (DIB), alleging disability due to physical and intellectual impairments starting September 1, 2019.
- The claim was denied at the initial and reconsideration stages. An ALJ held a hearing and again denied the claim, finding Manglik not disabled.
- The Appeals Council denied review, making the ALJ’s decision final. Manglik then sought judicial review in federal court.
- Evidence included IQ evaluations, psychological opinions, work and academic history (with significant accommodations), and testimony about daily activities and physical impairments.
- The ALJ found Manglik had several severe impairments (including intellectual disability) but only moderate functional limitations and retained the capacity for certain light, unskilled work.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ’s evaluation of Listing 12.05 (Intellectual Disorder) | Manglik met Listing 12.05B; ALJ cherry-picked or mischaracterized record showing marked/extreme limitations. | Substantial evidence supports ALJ’s findings of moderate limitations, considering work, education, and functioning. | ALJ’s decision supported by substantial evidence; moderate limitations found, Listing 12.05B not met. |
| ALJ’s evaluation of Dr. Chandi’s opinion | ALJ failed to conduct full supportability and consistency analysis; evidence supports greater limitations in standing/walking. | ALJ’s decision is supported elsewhere in record; inconsistent and unsupported opinions properly discounted. | Any error in supportability discussion was harmless; substantial evidence supports decision. |
Key Cases Cited
- Coffman v. Bowen, 829 F.2d 514 (4th Cir. 1987) (substantial evidence standard for review of Commissioner's factual findings)
- Laws v. Celebrezze, 368 F.2d 640 (4th Cir. 1966) (definition of substantial evidence in Social Security cases)
- Mastro v. Apfel, 270 F.3d 171 (4th Cir. 2001) (role of the court in reviewing Social Security determinations)
- Sterling Smokeless Coal Co. v. Akers, 131 F.3d 438 (4th Cir. 1997) (requirement that ALJ adequately explain findings)
- Sullivan v. Zebley, 493 U.S. 521 (1990) (impairment must meet all listing criteria to satisfy a Listing)
- Radford v. Colvin, 734 F.3d 288 (4th Cir. 2013) (ALJ must explain determination that claimant's impairment does not meet a Listing)
- Hancock v. Astrue, 667 F.3d 470 (4th Cir. 2012) (court’s limited role and deference to ALJ's weighing of the record)