United States District Court, D. Connecticut
ROBIN L. KNUDSEN, Plaintiff,
CAROLYN W. COLVIN, ACTING COMMISSIONER, SOCIAL SECURITY ADMINISTRATION, Defendant.
RULING ADOPTING RECOMMENDED RULING AFFIRMING THE DECISION OF THE COMMISSIONER AND DENYING MOTION TO REVERSE THE DECISION OF THE COMMISSIONER
Charles S. Haight, Jr. Senior United States District Judge
On May 30, 2014, Plaintiff Robin L. Knudsen filed the instant action pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3), seeking review of a March 29, 2013 final decision issued by Administrative Law Judge ("ALJ") Matthew Kuperstein of the Social Security Administration. Doc.
1. The ALJ's decision upheld the denial of Plaintiff's application for disability benefits under the Social Security Act. Administrative Record ("AR.") 17-35. Following cross-motions, Magistrate Judge Sarah A. L. Merriam issued a thorough 39-page recommended ruling on June 10, 2015 (the "Recommended Ruling" or "RR"), which found grounds to uphold the ALJ's decision and thereby grant the Commissioner's motion and deny that of the Plaintiff. Doc. 21. Plaintiff filed a timely objection to the Recommended Ruling. Doc. 22. This Ruling resolves that objection.
I. Standard of Review
The standard of review for a district court's evaluation of a magistrate judge's recommended ruling depends on whether a party has filed a timely written objection to the magistrate judge's "proposed findings and recommendations." 28 U.S.C. § 636(b)(1). Written objections are timely if the objecting party serves and files them "within fourteen days after being served with a copy" of the magistrate judge's proposed findings and recommendations. Id. The statute further provides: "A judge of the court shall make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made." Id. That obligation requires the reviewing judge, in a case where social security benefits have been denied, to "conduct a plenary review of the administrative record to determine if there is substantial evidence, considering the record as a whole, to support the Commissioner's decision and if the correct legal standards have been applied." Shaw v. Chater, 221 F.3d 126, 131 (2d Cir. 2000); see also Burgess v. Astrue, 537 F.3d 117, 127-28 (2d Cir. 2008). "Substantial evidence means 'more than a mere scintilla. It means such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.'" Burgess, 537 F.3d at 127 (quoting Halloran v. Barnhart, 362 F.3d 28, 31 (2d Cir. 2004)).
However, a district court reviews only for "clear error" those portions of a magistrate judge's recommended ruling as to which no specific objection was made. See Thomas v. Arn, 474 U.S. 140, 150 (1985) (Congress did not intend to "require district court review of a magistrate's factual or legal conclusions, under a de novo or any other standard, when neither party objects to those findings"); Bandhan v. Lab. Corp. of Am., 234 F.Supp.2d 313, 316 (S.D.N.Y. 2002) (a "district court evaluating a Magistrate's report may adopt those portions of the report to which no 'specific, written objection' is made, as long as those sections are not clearly erroneous" (quoting Fed.R.Civ.P. 72(b)).
In sum, I will conduct a de novo review of objected-to portions of the Recommended Ruling, thereby reviewing the ALJ's decision as to those subjects for "substantial evidence." I will review the remainder of the Recommended Ruling under a "clearly erroneous" standard.
A. Plaintiff's Objections to the Recommended Ruling
Plaintiff objects to the Recommended Ruling on two discrete grounds. First, Plaintiff argues that Judge Merriam improperly disregarded Plaintiff's "severe delusional disorder" and the impact that it should have had on the ALJ's analysis of Plaintiff's capacity. Second, Plaintiff argues that Judge Merriam failed to properly weigh the opinion evidence of Dr. David Guggenheim, a psychologist who reviewed Plaintiff's mental condition. I will review these aspects of the Recommended Ruling de novo (and, therefore, these elements of the ALJ decision for "substantial evidence").
1. Plaintiff's "Severe Delusional Disorder"
Plaintiff argues that the "Recommended Ruling improperly disregards Ms. Knudsen's severe delusional disorder." Doc. 22-1, at 1. At the outset, Plaintiff argues that the ALJ improperly relied on Plaintiff's overly-optimistic testimony in determining that she was not impaired. Id. Reliance on the veracity of Plaintiff's testimony was improper, the argument goes, because she suffers from severe delusional disorder of which the ALJ was aware. In other words, the ALJ should not have credited the rosy picture Plaintiff painted of her abilities. Plaintiff then argues that, after discrediting her own testimony, there is not enough alternative support in the record for the ALJ's finding. Id. at 1-3. Specifically, Plaintiff argues that Judge Merriam erred in her holding that the opinions of Drs. Hossein Samai, Mark Waynik, and Katie Carhart provided such alternative independently sufficient support. Id. For the reasons discussed below, this objection is without merit.
At the outset, it must be stated that Plaintiff's objection can only be understood as attacking the Recommended Ruling's Step Three analysis. Specifically, with respect to this argument, Plaintiff objects to the following statement from the Recommended Ruling:
Plaintiff's primary argument is that Plaintiff's delusions cause her to exaggerate her personal levels of functioning. Even if Plaintiff's statements were not considered, the opinions of the state reviewers, Dr. Carhart, Dr. ...