Buck v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedAugust 29, 2025
Docket2:24-cv-03194
StatusUnknown

This text of Buck v. Commissioner of Social Security (Buck 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
Buck v. Commissioner of Social Security, (S.D. Ohio 2025).

Opinion

SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

ALISA B.1 Case No. 2:24-cv-3194

Plaintiff, Bowman, M.J.

v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

MEMORANDUM OPINION AND ORDER

Plaintiff Alisa B. filed this Social Security appeal to challenge the Defendant’s finding that she is not disabled. See 42 U.S.C. §405(g). For the reasons explained below, the ALJ’s finding of non-disability should be AFFIRMED. I. Summary of Administrative Record On April 15, 2021, Plaintiff filed an application for Disability Insurance Benefits (“DIB”), as well as an application for supplemental security income (“SSI”), alleging that she became disabled beginning July 1, 2017 based on a combination of mental and physical impairments. During the alleged disability period, she engaged in substantial gainful activity at times, including a period of time in 2022 when she worked fulltime as a dishwasher at a local restaurant. (R. 25-26.) In April 2023 at the time of the ALJ’s decision, Plaintiff continued to be employed in the same position, but only part-time. (Id.)

1Due to significant privacy concerns in social security cases, the Court refers to claimants only by their first names and last initials. See General Order 22-01. 1 Plaintiff requested an evidentiary hearing before an Administrative Law Judge (“ALJ”). At a telephonic hearing held on March 16, 2023, Plaintiff appeared with counsel and gave

testimony before ALJ Jennifer Lash; a vocational expert also testified. (R. 45-68.) On April 18, 2023, the ALJ issued an adverse written decision. (R. 23-40.) The Appeals Council denied further review, leaving the ALJ’s decision as the final decision of the Commissioner. Plaintiff then filed this judicial appeal. Plaintiff has a high school education and no past relevant work involving transferable skills. She was 23 years old on the date of her alleged onset of disability, which is considered a “younger individual,” and remained in the same age category through the date of the ALJ’s decision. She lives with her fiancé and three minor children. Based on her work history, she met insured status requirements for DIB only through September 30, 2019.2 (R. 25.)

The ALJ determined that Plaintiff has the following severe impairments: “disorders of the spine, right ankle disorder, asthma, disorders of the female genital organs, anemia and thrombosis with factor V disorder, depressive disorder, anxiety disorder, attention deficit hyperactivity disorder (ADHD), and trauma- and stressor-related disorder.” (R. 26.) The ALJ also found the following non-severe physical impairments: hypersomnia, appendicitis, right hand and finger lacerations, lung nodules, right shoulder tendonitis,

2The DIB and SSI regulations are virtually identical. That said, because Plaintiff’s date last insured for DIB expired on September 30, 2019, Plaintiff was required to prove that she became disabled before that date in order to be entitled to DIB. After her insured status expired, she remained eligible for SSI benefits upon proof of disability. But SSI regulations preclude the receipt of SSI benefits for any month prior to that in which Plaintiff filed the application. See 20 C.F.R. § 416.335. Accordingly, the period relevant to the determination of Plaintiff’s SSI claim falls between April 15, 2021 and April 18, 2023, the date of the ALJ’s decision. See 20 C.F.R. § 416.305 (identifying the filing of an SSI application as a requirement in becoming eligible to receive such benefits). 2 oppositional defiant disorder, but found no evidence that it was a medically determinable impairment. (Id.) Considering all of Plaintiff’s impairments, the ALJ concluded that none

of them met or medically equaled any Listing in 20 C.F.R. Part 404, Subpart P, Appendix 1, either alone or in combination, such that Plaintiff would be entitled to a presumption of disability. (Id.) The ALJ further determined that Plaintiff retains the residual functional capacity (“RFC”) to perform a range of light work, subject to additional non-exertional limitations: [S]he can occasionally balance, stoop, kneel, crouch, and climb ramps and stairs; can never crawl or climb ladders, ropes, or scaffolds; must avoid concentrated exposure to extreme cold, extreme heat, wetness, humidity, vibration, and fumes, odors, dust, gases, and poor ventilation; must avoid all exposure to hazards including moving machinery and unprotected heights; can understand, remember, and carry out routine tasks requiring no more than normal breaks; can occasionally interact with the public, coworkers, and supervisors; can have no frequent changes in the work setting; and can have no fast-paced production demands.

(R. 31.) Based on the RFC as determined and in reliance on vocational expert testimony, the ALJ found that Plaintiff could still perform a substantial number of unskilled jobs existing in the national economy, including the representative positions of office helper, router, and mail clerk. (R. 39.) Therefore, the ALJ concluded that Plaintiff was not under a disability at any point in time through the date of her decision. (R. 40.) II. Judicial Standard of Review To be eligible for benefits, a claimant must be under a “disability.” See 42 U.S.C. §1382c(a). Narrowed to its statutory meaning, a “disability” includes only physical or mental impairments that are both “medically determinable” and severe enough to prevent the applicant from (1) performing his or her past job and (2) engaging in “substantial 3 of New York, 476 U.S. 467, 469-70 (1986). When a court is asked to review the Commissioner’s denial of benefits, the court’s

first inquiry is to determine whether the ALJ’s non-disability finding is supported by substantial evidence. 42 U.S.C. § 405(g). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971) (additional citation and internal quotation omitted). In conducting this review, the court should consider the record as a whole. Hephner v. Mathews, 574 F.2d 359, 362 (6th Cir. 1978). If substantial evidence supports the ALJ’s denial of benefits, then that finding must be affirmed, even if substantial evidence also exists in the record to support a finding of disability. Felisky v. Bowen, 35 F.3d 1027, 1035 (6th Cir. 1994). As the Sixth Circuit has explained: The Secretary’s findings are not subject to reversal merely because substantial evidence exists in the record to support a different conclusion.... The substantial evidence standard presupposes that there is a ‘zone of choice’ within which the Secretary may proceed without interference from the courts. If the Secretary’s decision is supported by substantial evidence, a reviewing court must affirm.

Id. (citations omitted); see also Biestek v.

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Buck v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/buck-v-commissioner-of-social-security-ohsd-2025.