Bowers v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedNovember 20, 2023
Docket2:22-cv-04253
StatusUnknown

This text of Bowers v. Commissioner of Social Security (Bowers v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, S.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bowers v. Commissioner of Social Security, (S.D. Ohio 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

LAURA B.,1

Plaintiff,

v. Civil Action 2:22-cv-4253 Magistrate Judge Chelsey M. Vascura

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

OPINION AND ORDER Plaintiff, Laura B. (“Plaintiff”), brings this action under 42 U.S.C. § 405(g) for review of a final decision of the Commissioner of Social Security (“Commissioner”) denying her application for Social Security Period of Disability and Disability Insurance benefits. This matter, in which the parties have consented to the jurisdiction of the Magistrate Judge pursuant to 28 U.S.C. § 636(c), is before the undersigned for a ruling on Plaintiff’s Statement of Errors (ECF No. 13), Commissioner’s Memorandum in Opposition (ECF No. 16), and the administrative record (ECF No. 9). Plaintiff did not file a reply memorandum. For the reasons that follow, Plaintiff’s Statement of Errors is OVERRULED and the Commissioner’s decision is AFFIRMED.

1 Pursuant to this Court’s General Order 22-01, any opinion, order, judgment, or other disposition in Social Security cases shall refer to plaintiffs by their first names and last initials. I. BACKGROUND Plaintiff protectively filed her application for Title II period of disability and disability insurance benefits on October 13, 2020, alleging that she became disabled on May 10, 2019. After Plaintiff’s applications were denied at the initial and reconsideration levels, an administrative law judge (“ALJ”) held a telephone hearing on October 6, 2021, and issued an

unfavorable determination on November 1, 2021. That unfavorable determination became final on September 27, 2022, when the Appeals Council denied Plaintiff’s request for review. Plaintiff seeks judicial review of that final determination. Plaintiff asserts two contentions of error: (1) the ALJ’s residual functional capacity (“RFC”) determination is not supported by substantial evidence (specifically related to Plaintiff’s ability to stand and walk); and (2) the ALJ erred in his analysis of Plaintiff’s fibromyalgia under Social Security Ruling 12-2p. (Pl.’s Statement of Errors 4–11, ECF No. 13.) The undersigned disagrees. II. THE ALJ’S DECISION On November 1, 2021, the ALJ issued a decision finding that Plaintiff was not disabled within the meaning of the Social Security Act. (R. 199–215.) At step one of the sequential evaluation process,2 the ALJ found that Plaintiff had not engaged in substantially gainful activity since the alleged onset date of May 10, 2019. (Id. at 201–02.) At step two, the ALJ found that Plaintiff had the following severe impairments: degenerative disc and joint disease of the lumbar spine and sacroiliac joints; sacroiliitis of the spine; fibromyalgia; obesity; and an adjustment disorder with mixed anxiety and depression. (Id. at 202.) The ALJ also found that Plaintiff had

the following non-severe impairments: tachycardia; hypertension, hordeolum of the left lower eyelid; and high cholesterol. (Id.) At step three, the ALJ found that Plaintiff did not have an impairment or combination of impairments that met or medically equaled one of the listed impairments described in 20 C.F.R. Part 404, Subpart P, Appendix 1. (Id. at 203–05.) The ALJ set forth Plaintiff's residual functional capacity (“RFC”) as follows: [Plaintiff] has the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) except [Plaintiff] could occasionally climb ramps/stairs, but would be precluded from climbing ladders/ropes/scaffolds. She could occasionally stoop, kneel, crouch, and crawl. The claimant should avoid workplace hazards, such as unprotected heights and machinery. The claimant could perform simple, routine and repetitive tasks, involving only simple work related decisions, with few if any work place changes. She could work in a setting without strict production quotas

2 Social Security Regulations require ALJs to resolve a disability claim through a five-step sequential evaluation of the evidence. See 20 C.F.R. § 404.1520(a)(4). Although a dispositive finding at any step terminates the ALJ’s review, see Colvin v. Barnhart, 475 F.3d 727, 730 (6th Cir. 2007), if fully considered, the sequential review considers and answers five questions: 1. Is the claimant engaged in substantial gainful activity? 2. Does the claimant suffer from one or more severe impairments? 3. Do the claimant’s severe impairments, alone or in combination, meet or equal the criteria of an impairment set forth in the Commissioner’s Listing of Impairments, 20 C.F.R. Subpart P, Appendix 1? 4. Considering the claimant’s residual functional capacity, can the claimant perform his or her past relevant work? 5. Considering the claimant’s age, education, past work experience, and residual functional capacity, can the claimant perform other work available in the national economy? See 20 C.F.R. § 404.1520(a)(4); see also Henley v. Astrue, 573 F.3d 263, 264 (6th Cir. 2009); Foster v. Halter, 279 F.3d 348, 354 (6th Cir. 2001). or fast paced work, such as on an assembly line. The claimant could have occasional interaction with the general public, coworkers, and supervisors, with no customer service responsibilities. (Id. at 205.) The ALJ then determined at step four that that Plaintiff would be unable to perform her past relevant work as either a loss prevention worker or private investigator. (Id. at 214.) At step five, the ALJ, relying upon a vocational expert, found that jobs exist in significant numbers in the national economy that an individual with Plaintiff’s age, education, work experience, and residual functional capacity can perform, with representative occupations being mail sorter, garment sorter, or marker. (Id. at 214–15.) The ALJ therefore concluded that Plaintiff was not disabled under the Social Security Act during the relevant period. (Id. at 215.) III. STANDARD OF REVIEW When reviewing a case under the Social Security Act, the Court “must affirm a decision by the Commissioner as long as it is supported by substantial evidence and was made pursuant to proper legal standards.” DeLong v. Comm’r of Soc. Sec., 748 F.3d 723, 726 (6th Cir. 2014) (cleaned up); see also 42 U.S.C. § 405(g) (“The findings of the Commissioner of Social Security as to any fact, if supported by substantial evidence, shall be conclusive . . . .”). While this

standard “requires more than a mere scintilla of evidence, substantial evidence means only such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Moats v. Comm’r of Soc. Sec., 42 F.4th 558, 561 (6th Cir. 2022) (cleaned up) (quoting Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019)). Although the substantial evidence standard is deferential, it is not trivial. The Court must “examine[ ] the record as a whole and take[ ] into account whatever in the record fairly detracts from the weight” of the Commissioner’s decision. Golden Living Ctr.-Frankfort v.

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