Brown v. Commissioner of Social Security

District Court, S.D. Ohio·Decided March 31, 2025·No. 1:23-cv-00690·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO WESTERN DIVISION - CINCINNATI ASHLEY B., : Case No. 1:23-cv-690 Plaintiff, Judge Matthew W. McFarland : COMMISSIONER OF SOCIAL SECURITY, Defendant.

ENTRY AND ORDER DECLINING TO ADOPT REPORT AND RECOMMENDATION (Doc. 11)

This matter is before the Court on the Report and Recommendation of United States Magistrate Judge Peter B. Silvain, Jr., (Doc. 11), to whom this case is referred pursuant to 28 U.S.C. § 636(b). Plaintiff Ashley B. brought this action pursuant to 42 US.C. § 405(g) for judicial review of the Defendant Commissioner of Social Security’s non-disability determination. In the Report and Recommendation (Doc. 11), the Magistrate Judge recommended that: (1) this Court sustain Plaintiff's Statement of Errors (Doc. 8); (2) vacate the Commissioner’s non-disability finding; and (3) make no finding of Plaintiff's disability status but remand the case to the Social Security Administration for further consideration. (Report, Doc. 11, Pg. ID 2145.) Defendant filed Objections (Doc. 13). Plaintiff then filed a Response to Defendant's Objections (Doc. 14). Thus, the matter is ripe for review.

Pursuant to 28 U.S.C. § 636(b) and Federal Rule of Civil Procedure Rule 72(b), the Court has made a de novo review of the record in this case. Judicial review of an administrative law judge’s (“ ALJ”) decision is limited to whether the AL]’s findings are supported by substantial evidence and whether the ALJ applied the correct legal standards. Blakley v. Comm’r of Soc. Sec., 581 F.3d 399, 406 (6th Cir. 2009). Substantial evidence is “relevant evidence that a reasonable mind might accept as adequate to support a conclusion.” Gentry v. Comm’ of Soc. Sec., 741 F.3d 708, 722 (6th Cir. 2014). It is “less than a preponderance but more than a scintilla.” Id. The second judicial inquiry — reviewing the correctness of the ALJ's legal analysis— may result in reversal even if the ALJ's decision is supported by substantial evidence in the record. Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647, 651 (6th Cir. 2009). Defendant objects to the Report and Recommendation based on its application of the Deskin rule. (Objections, Doc. 13, Pg. ID 2149.) Defendant argues that both its originating court and this Court have since rejected the rule, which “runs afoul” of the ALJ's authority. (Id. at Pg. ID 2149, 2152.) Further, Defendant argues that the Deskin rule conflicts with Sixth Circuit case law. (Id. at Pg. ID 2152.) The Magistrate Judge relied, in part, on Deskin v. Commissioner of Social Security, 605 F. Supp. 2d 908 (N.D. Ohio 2008), in deciding to recommend remand for further consideration of Plaintiff's medical records. (Report, Doc. 11, Pg. ID 2138-39.) While the Report declines to assert that Plaintiff has a disability under the Social Security Act, it recommends vacating the current ALJ’s determination because the ALJ “did not sufficiently make the connection” between the evidence relied on and the conclusion

reached. (Id. at Pg. ID 2143.) In other words, the evidence that the AL] relied on was not subject to the ALJ’s commonsense judgment. (Id. (citing Tucker v. Comm’ of Soc. Sec., 775 F, App’x 220, 226 (6th Cir. 2019)).) To reach this conclusion, the Report applies the Deskin rule; Defendant objects to this application. In Deskin, the District Court for the Northern District of Ohio held that “where the transcript contains only diagnostic evidence and no opinion from a medical source about functional limitations (or only an outdated non-examining agency opinion), to fulfill the responsibility to develop a complete record, the ALJ must recontact the treating source, order a consultative examination, or have a medical expert testify at the hearing.” 605 F. Supp. 2d at 912. As the Report points out, the rule “potentially applies only” in those two cases of an under-developed record of diagnostic evidence. (Report, Doc. 11, Pg. ID 2139.) Still, under the Deskin rule, the ALJ “retains discretion to impose work-related limitations without a proper source opinion where the medical evidence shows relatively little physical impairment and the ALJ can render a commonsense judgment about functional capacity.” Kyzys v. Comm’r of Soc. Sec., No. 3:10-CV-25, 2011 WL 5024866, at *2 (N.D. Ohio Oct. 21, 2011) (cleaned up). The Report found that the last medical opinion in Plaintiff's record came from 2020, but the record also contained CT scans from 2022, and the ALJ relied, in part, on these later scans. (Doc. 11, Pg. ID 2140.) Thus, the Report recommends that, under the rule, the ALJ’s decision should be remanded because the ALJ relied on evidence without a medical opinion (the later CT scans), and such evidence fell outside the scope of the ALJ’s commonsense judgment. (/d.)

Defendant disagrees. First, Defendant points out that Deskin has been “rejected by both its originating court and this Court.” (Objections, Doc. 13, Pg. ID 2150.) In support of this argument, Defendant cites Northern District of Ohio case law which stated that Deskin “conflicts with the regulations and Sixth Circuit case law.” (Id. at Pg. ID 2150-51; Carr v. Comm’r of Soc. Sec., No. 5:23-CV-187, 2024 WL 1343473, at *5 (N.D. Ohio Mar. 30, 2024); see also Williams v. Astrue, No. 1:11-CV-1569, 2012 WL 3586962, at *7 (N.D. Ohio Aug. 12, 2021) (“But [residual functional capacity] is for the ALJ to determine, see 20 C.F.R. § 416.945(a).”)) And, this Court found similarly: “Deskin has been criticized by nearly two dozen cases, including this Court,” as “not representative of the law established by the legislature, and [as] interpreted by the Sixth Circuit Court of Appeals.” Lawson v. Comm’r of Soc. Sec., No. 1:20-CV-324, 2021 WL 2659176, at *9 (S.D. Ohio June 29, 2021), report and recommendation adopted, 2021 WL 3663649 (S.D. Ohio Aug. 18, 2021) (quotation omitted). Further, the law and this Court have made clear that the ALJ, when determining the residual functional capacity (“RFC”) of a claimant, has “discretion to seek additional or clarifying information” if the information on the record is insufficient. (Objections, Doc. 13, Pg. ID 2151; see also 20 C.F.R. § 416.920b.) Code of Federal Regulations § 416.920b describes how the AL] considers evidence in making an RFC determination. The process gives exclusive control over the consideration of evidence to the ALJ and does not mention any requirement of an ALJ to request a medical opinion for every piece of evidence. 20 C.F.R. § 416.920b. Defendant points not only to the Code, but also Sixth Circuit case law to establish that the ALJ has the sole responsibility to determine a claimant’s RFC. (Objections, Doc. 13, Pg. ID 2151 (citing Coldiron v. Comm’r Soc. Sec., 391

F. App’x 435, 439 (6th Cir. 2010)); see also Foster v. Halter, 279 F.3d 348, 355 (6th Cir.

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