Bohn-Morton v. Commissioner of Social Security

389 F. Supp. 2d 804, 2005 U.S. Dist. LEXIS 43215, 2005 WL 2433149
CourtDistrict Court, E.D. Michigan
DecidedSeptember 27, 2005
Docket04-72105
StatusPublished
Cited by1 cases

This text of 389 F. Supp. 2d 804 (Bohn-Morton v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bohn-Morton v. Commissioner of Social Security, 389 F. Supp. 2d 804, 2005 U.S. Dist. LEXIS 43215, 2005 WL 2433149 (E.D. Mich. 2005).

Opinion

OPINION AND ORDER REGARDING MAGISTRATE JUDGE’S REPORT AND RECOMMENDATION

ROSEN, District Judge.

On June 22, 2005, Magistrate Judge Wallace Capel, Jr. issued a Report and Recommendation (“R & R”) recommending that the Court grant in part Plaintiff Denise Bohn-Morton’s Motion for Summary Judgment, deny the Defendant Commissioner of Social Security’s Motion for Summary Judgment, and remand this case for further administrative proceedings. Defendant filed objections to the R & R on July 7, 2005, and Plaintiff filed a response to these objections on July 14, 2005. The Court has now reviewed the parties’ motions, the R & R, Defendant’s objections, Plaintiffs response, and the other materials in the record. For the reasons discussed briefly below, the Court finds Defendant’s objections well-taken, and concludes that its summary judgment motion should be granted and Plaintiffs motion denied.

As observed in the R & R, this case has returned to this Court following a prior remand for further administrative proceedings. In an earlier round of judicial proceedings, the Court determined that the questioning of the vocational expert (“VE”) by the Administrative Law Judge (“ALJ”) did not properly incorporate the ALJ’s findings regarding Plaintiffs non-exertional limitations. Rather, the ALJ’s hypothetical questioning of the VE included only exertional limitations, with the ALJ then reasoning in his decision that a general limitation to “unskilled” work would sufficiently ensure that Plaintiff would be able to perform the jobs identified in the VE’s testimony notwithstanding her non-exertional limitations. (See Admin. Record at 20.) The Court held that this was error, reasoning that the ALJ’s generalized limitation to unskilled work did not adequately incorporate the specific non-exertional limitations that necessarily must have existed in light of the ALJ’s determination that Plaintiff “often” suffered from a deficiency of concentration, persistence, or pace. Accordingly, the case was remanded so that the ALJ could further question the VE in a manner that properly encompassed all of Plaintiffs limitations, exertional and non-exertional alike.

Consequently, the question before this Court is whether the ALJ properly heeded this instruction on remand. 1 The Magistrate Judge recommends that this question be answered in the negative, observing that the sole additional limitation incorporated into the ALJ’s hypothetical questioning of the VE upon remand was a limitation to “simple and rote type job tasks.” (Admin. Record at 385.) The Magistrate *806 Judge reasons that this limitation did not properly “incorporate both concentration difficulties and problems related to timely completion of tasks as a result,” (R & R at 13), as purportedly required under the Sixth Circuit’s decision in Smith v. Halter, 307 F.3d 377 (6th Cir.2001).

The Court agrees with Defendant that the R & R rests upon an unduly rigid reading of the ruling in Smith. In that case, as here, the ALJ determined that the claimant, Daniel Smith, “often” suffered deficiencies in concentration, persistence or pace. See Smith, 307 F.3d at 378. In subsequent questioning of the VE, the ALJ “characterized [Smith’s] mental impairment as limiting him to jobs that are routine and low stress, and do not involve intense interpersonal confrontations, high quotas, unprotected heights, or operation of dangerous machinery.” 307 F.3d at 378. Smith argued that this questioning should have explicitly incorporated the ALJ’s finding that he “ ‘often’ suffers deficiencies in concentration, persistence, or pace resulting in failure to complete tasks in a timely manner,” but the Court disagreed:

The ALJ’s “finding” Smith relies on here — that Smith “often” has problems concentrating that preclude him from completing tasks on time- — was a single box the ALJ checked in a 1-5 rating scale on a standard psychiatric assessment form. But the ALJ went beyond this simple frequency assessment to develop a complete and accurate assessment of Smith’s mental impairment.... In particular, the ALJ relied on the testimony of four physicians who characterized Smith’s concentration problems as minimal or negligible. The ALJ then translated Smith’s condition into the only concrete restrictions available to him — examining psychiatrist Schweid’s recommended restrictions against quotas, complexity, stress, etc. — and duly incorporated them into his hypothetical to the vocational expert.

307 F.3d at 377. Accordingly, the Court concluded that “the ALJ accurately characterized Smith’s impairments in his hypothetical to the vocational expert.” 307 F.3d at 377.

In so ruling, the Court distinguished various unpublished district court decisions. The Court observed that, in two of these decisions, “the ALJs ... appear to have made no attempt to incorporate concentration difficulties in their instructions to the vocational expert.” 307 F.3d at 377. In another, the court faulted the ALJ for imposing only a limitation to “simple tasks,” where the ALJ previously had determined “that concentration problems might preclude timely completion of work.” 307 F.3d at 380 (discussing McGuire v. Apfel, No. 98-1302-ST, 1999 WL 426035, at *15-16 (D.Or. May 11, 1999)). The Sixth Circuit reasoned that McGuire was distinguishable because “[h]ere, the ALJ’s restriction against jobs with quotas adequately addresses that timeliness issue.” Smith, 307 F.3d at 380.

In recommending in this case that the ALJ’s questioning should be deemed deficient, the Magistrate Judge seemingly focuses on this last passage in the Smith decision. The ALJs in Smith and in this case checked the same box on a Psychiatric Review Technique Form (“PRTF”), indicating that the claimants “often” suffered from deficiencies of concentration, persistence, or pace resulting in failure to complete tasks in a timely manner. (See Admin. Record at 29.) Yet, while the ALJ in Smith limited the claimant to positions that did not involve high quotas, the ALJ here did not explicitly incorporate a timeliness component into his questioning of the VE, but instead imposed a more general limitation to “simple and rote type job tasks.” (See id. at 385.) Absent a *807 specific reference to timely completion of tasks, the Magistrate Judge reasons that this questioning runs afoul of the ruling in Smith.

The Court agrees with Defendant that Smith does not mandate an explicit timeliness-related limitation whenever an ALJ makes a finding in a PRTF that a claimant “often” experiences deficiencies in concentration, persistence, or pace. Initially, the Court notes its own prior decision that an ALJ properly incorporated findings of “moderate limitations in concentration, social functioning, and tolerance of stress” by restricting his questioning of a VE to “work involving only a ‘mild’ amount of stress and only ‘simple one, two or three step operations.’ ” Smith-Felder v. Commissioner of Social Security, 103 F.Supp.2d 1011, 1014 (E.D.Mich.2000).

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Cite This Page — Counsel Stack

Bluebook (online)
389 F. Supp. 2d 804, 2005 U.S. Dist. LEXIS 43215, 2005 WL 2433149, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bohn-morton-v-commissioner-of-social-security-mied-2005.