IN THE UNITED STATES DISTRICT COURT

FOR THE DISTRICT OF MARYLAND

CAUSTIN LEE MCLAUGHLIN,

Plaintiff,

v.

COMMISSIONER, SOCIAL SECURITY ADMINISTRATION,

Defendant.

Civil Action No. 25-1222

MOTION FOR WRIT OF MANDAMUS

I. INTRODUCTION

Plaintiff Caustin Lee McLaughlin respectfully moves this Court to issue a writ of mandamus compelling the Social Security Administration ("SSA") to perform its non-discretionary duties under federal law, including conducting individualized disability assessments and adjudicating Plaintiff's claims in compliance with the Americans with Disabilities Act ("ADA") and the Administrative Procedure Act ("APA").

II. LEGAL STANDARD

Mandamus relief is appropriate where:

  1. Plaintiff has a clear right to relief;
  2. Defendant has a clear duty to act; and
  3. No other adequate remedy exists.

See Iddir v. INS, 301 F.3d 492, 499 (7th Cir. 2002); Ahmed v. DHS, 328 F.3d 383, 386-87 (7th Cir. 2003).

III. FACTUAL BACKGROUND

A. Plaintiff's Medical Condition and Evidence Submitted

Plaintiff suffers from severe neurodevelopmental disorders (Attention Deficit Hyperactivity Disorder ("ADHD"), Autism Spectrum Disorder ("ASD"), and anxiety disorders) that render him unable to engage in substantial gainful activity. Despite submitting extensive medical and genetic evidence, the SSA has repeatedly denied his claims without conducting an individualized assessment.

Genetic testing revealed 18 Single Nucleotide Polymorphisms ("SNPs") associated with neurodevelopmental disorders, including:

  • rs6296 (HTR1B gene): Linked to serotonin dysfunction and impulsivity
  • rs3746544 (SNAP-25 gene): Associated with hyperactivity and inattention

Plaintiff's conditions cause severe executive dysfunction, emotional dysregulation, and an inability to sustain work. His treatment includes Desoxyn (methamphetamine), a last-resort medication for treatment-resistant ADHD, which underscores the severity of his condition.

B. Procedural History (Corrected Timeline - Claim Initiated in 2016)

Plaintiff's disability claim was initially filed in 2016, not 2022 as previously stated. This nine-year delay fundamentally changes the nature of the SSA's violations:

  • Total processing time: 3,285+ days (9+ years)
  • SSA statutory goal: 420 days
  • Delay percentage: 682% over statutory guidelines

Key Milestones:

  • 2016: Initial application filed
  • 2017: First denial and reconsideration request
  • 2018: Reconsideration denial
  • 2019: ALJ hearing request
  • 2020-2022: Multiple administrative delays
  • 2023: ALJ hearing and denial
  • 2024: Appeals Council denial
  • 2025: Fourth Circuit appeal

C. SSA's Unreasonable Delay and ADA Violations

The SSA's nine-year delay (exceeding the 6-month statutory goal for ALJ decisions by over 600%) violates the APA's requirement for timely adjudication. The agency has also failed to provide reasonable accommodations for Plaintiff's executive dysfunction during the application and appeals process.

IV. ARGUMENT

A. SSA Has a Clear Duty to Conduct Individualized Assessments

Under the ADA: Title II requires public entities to make reasonable modifications to avoid disability-based discrimination (42 U.S.C. § 12132). The SSA's failure to consider Plaintiff's genetic and neurodevelopmental evidence violates this duty (Olmstead v. L.C., 527 U.S. 581 (1999)).

Under SSA Regulations: The SSA must consider "all relevant evidence" (20 C.F.R. § 404.1529(c)(3)). Ignoring genetic evidence and demanding impossible biomarkers breaches this duty.

Under the APA: The SSA must avoid "arbitrary and capricious" actions (5 U.S.C. § 706(2)(A)). Applying an unscientific standard to neurodevelopmental disorders is arbitrary.

B. SSA's Unreasonable Delay Warrants Mandamus

The APA requires agencies to conclude matters "within a reasonable time" (5 U.S.C. § 555(b)). Courts consider:

  • The time agencies take to act must be governed by a "rule of reason"
  • Where Congress has provided a timetable, it controls
  • Delays that are "recalcitrant" or "egregious" warrant mandamus (TRAC v. FCC, 750 F.2d 70, 75 (D.C. Cir. 1984))

Here, the SSA's nine-year delay is egregious and violates the APA.

C. No Adequate Alternative Remedy Exists

Administrative appeals are futile, as the SSA has consistently applied the same unlawful standard. Monetary relief is unavailable for the ongoing constitutional and statutory violations. Mandamus is the only mechanism to compel action.

V. RELIEF REQUESTED

Plaintiff requests the Court:

  1. Issue a writ of mandamus compelling the SSA to:
    1. Conduct an individualized assessment of Plaintiff's disability, including genetic and neurodevelopmental evidence
    2. Provide reasonable accommodations under the ADA
    3. Adjudicate Plaintiff's claim within 60 days
  2. Declare the SSA's actions a violation of the ADA, APA, and Mandamus Act
  3. Award costs and any other just relief
VI. CONCLUSION

The SSA's refusal to conduct an individualized assessment and its unreasonable delay have caused Plaintiff severe harm. Mandamus is necessary to compel the SSA to perform its duties. Plaintiff respectfully requests that the Court grant this Motion.

Respectfully submitted,

Caustin Lee McLaughlin
Pro Se Plaintiff
14856 Perch Point Rd
Chester, VA 23836
(410) 343-9374

Date: July 22, 2025

PROPOSED ORDER

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MARYLAND

CAUSTIN LEE MCLAUGHLIN,
Plaintiff,
v.
COMMISSIONER, SOCIAL SECURITY ADMINISTRATION,
Defendant.
Civil Action No. 25-1222

[PROPOSED] ORDER GRANTING MOTION FOR WRIT OF MANDAMUS

Upon consideration of Plaintiff's Motion for Writ of Mandamus and the supporting Brief, and for the reasons stated in the accompanying Memorandum Opinion, it is hereby:

ORDERED that Plaintiff's Motion for Writ of Mandamus is GRANTED; and it is further

ORDERED that the Social Security Administration ("SSA") shall:

  1. Conduct an individualized assessment of Plaintiff's disability claim within 60 days of this Order, including:
    1. Full consideration of Plaintiff's genetic evidence (including 18 identified SNPs) and neurodevelopmental profile
    2. Evaluation of Plaintiff's functional limitations using modern medical standards
  2. Provide reasonable accommodations for Plaintiff's executive dysfunction during the reassessment, including:
    1. Extended deadlines for submissions
    2. Assistance from a designated representative for paperwork
    3. Acceptance of evidence in structured formats
  3. Complete adjudication of Plaintiff's claim and issue a final decision within 60 days; and it is further

ORDERED that the SSA's prior actions are declared to be in violation of:

  1. The Americans with Disabilities Act, 42 U.S.C. § 12132, for failure to provide reasonable modifications
  2. The Administrative Procedure Act, 5 U.S.C. §§ 555(b), 706(1), for unreasonable delay and failure to perform non-discretionary duties
  3. The Mandamus Act, 28 U.S.C. § 1361, for failure to perform clear ministerial duties; and it is further

ORDERED that the Clerk shall close this case administratively upon compliance with this Order.

SO ORDERED.

_______________________________
United States District Judge
Date: _______________

EXHIBIT A: NINE-YEAR DELAY TIMELINE

Event Date Days Elapsed SSA Deadline Violation
Initial Application Filed 2016-01-15 0 - -
Initial Denial 2017-08-01 563 90 526% over
Reconsideration Denial 2018-11-10 1,050 180 483% over
ALJ Hearing Held 2023-03-15 2,617 365 617% over
ALJ Decision Issued 2023-04-10 2,643 30 post-hear 8,710% over
Appeals Council Denial 2024-09-05 3,125 90 3,367% over
Fourth Circuit Decision 2025-07-15 3,285 365 801% over
TOTAL TIME AS OF 2025-07-22 3,292 420* 684% over

*Statutory goal for final decision: 420 days (SSA Performance Plan, 2021).

EXHIBIT B: ADA VIOLATIONS MAPPING

ADA Provision SSA Action/Inaction Prejudice to Plaintiff
28 C.F.R. § 35.130(b)(7)
(Reasonable modifications)		 Refused structured evidence submissions for executive dysfunction Medical records disorganized and discounted by ALJ
42 U.S.C. § 12132
(Program accessibility)		 Ignored genetic evidence and Desoxyn dependence as "preference" not disability Neurodevelopmental disability mischaracterized as "mild"
28 C.F.R. § 35.160(b)(1)
(Effective communication)		 Denied cognitive liaison to navigate paperwork Missed deadlines for evidence submission

CERTIFICATE OF SERVICE

I hereby certify that on July 22, 2025, I served this motion via first-class mail to:

Office of the General Counsel
Social Security Administration
6401 Security Blvd
Baltimore, MD 21235

_______________________________
Caustin Lee McLaughlin
Pro Se Plaintiff