NICHOLLS v. COMMISSIONER OF THE SOCIAL SECURITY ADMINISTRATION
2:24-cv-07902
D.N.J.May 2, 2025Background
- Plaintiff M.N. appealed the Social Security Commissioner’s denial of his application for disability insurance benefits, with alleged disability onset on July 6, 2021.
- After a hearing before ALJ Karen Shelton in June 2023, the ALJ found Plaintiff not disabled in a September 2023 decision.
- The ALJ determined Plaintiff did not meet or equal any Listings and retained capacity for sedentary work despite certain limitations, but could not perform past relevant work.
- At step five, a vocational expert identified significant jobs Plaintiff could perform given his limitations.
- Plaintiff appealed, arguing errors in the ALJ’s findings, development of the record, and the vocational expert’s analysis; the district court reviewed under the substantial evidence standard.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Step 4 RFC supported by evidence? | ALJ erred in finding Plaintiff could stand/walk two hours/day | ALJ cited extensive medical evidence and expert opinion supporting RFC | Court found step 4 conclusion supported |
| Failure to develop mental health record? | ALJ did not adequately investigate mental health limitations | Record was complete, with substantial mental evaluations and records | Record development was sufficient |
| ALJ cherry-picked evidence? | ALJ ignored key psychiatrist limitations in opinion | ALJ considered those limitations and discussed them in decision | No cherry-picking; ALJ addressed evidence |
| Vocational expert error at step five? | Vocational expert’s analysis was flawed | Plaintiff waived cross-examination and cannot reweigh evidence on appeal | No error; substantial evidence supports ALJ |
Key Cases Cited
- Bowen v. Yuckert, 482 U.S. 137 (establishes claimant's burden at first four steps of disability analysis)
- Shinseki v. Sanders, 556 U.S. 396 (burden falls on claimant to show harmful error in agency determination)
- Monsour Med. Ctr. v. Heckler, 806 F.2d 1185 (court cannot reweigh evidence or substitute judgment for agency)
- Williams v. Sullivan, 970 F.2d 1178 (district court may not substitute its conclusions for fact-finder's)