Cowles v. Social Security, Commissioner of

CourtDistrict Court, E.D. Michigan
DecidedFebruary 13, 2025
Docket2:24-cv-10284
StatusUnknown

This text of Cowles v. Social Security, Commissioner of (Cowles v. Social Security, Commissioner of) 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
Cowles v. Social Security, Commissioner of, (E.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

NICHOLAS C., Case No. 24-cv-10284 Plaintiff, Magistrate Judge Elizabeth A. Stafford v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

OPINION AND ORDER ON CROSS-MOTIONS FOR SUMMARY JUDGMENT (ECF NOS. 11, 13)

I. Introduction Plaintiff Nicholas C. appeals the final decision of defendant Commissioner of Social Security (Commissioner), which denied his application for disability insurance benefits (DIB) under the Social Security Act. Both parties have filed summary judgment motions and consented to the undersigned conducting all proceedings under 28 U.S.C. § 636(c). ECF No. 10; ECF No. 11; ECF No. 13. After review of the record, the Court ORDERS that: • Plaintiff’s motion (ECF No. 11) is DENIED; • the Commissioner’s motion (ECF No. 13) is GRANTED; and • the ALJ’s decision is AFFIRMED under sentence four of 42 U.S.C. § 405(g).

II. Background A. Plaintiff’s Background and Disability Application Born in May 1979, plaintiff was 43 years old when he applied for DIB

in September 2022, with an alleged disability onset date of September 15, 2021. ECF No. 6-1, PageID.35, 40. He had past relevant work as a diesel mechanic and forklift mechanic. Id., PageID.40. Plaintiff claimed disability from psychosis, depression, low back issues, and obesity. Id., PageID.86.

After a hearing, during which plaintiff and a vocational expert (VE) testified, the ALJ found plaintiff not disabled. Id., PageID.35, 41. The Appeals Council denied review, making the ALJ’s decision the final

decision of the Commissioner. Id., PageID.21. Plaintiff timely filed for judicial review. ECF No. 1. B. The ALJ’s Application of the Disability Framework Analysis

A “disability” is the “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.”

42 U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A). The Commissioner determines whether an applicant is disabled by analyzing five sequential steps. First, if the applicant is “doing substantial

gainful activity,” he or she will be found not disabled. 20 C.F.R. § 404.1520(a)(4). Second, if the claimant has not had a severe impairment or a combination of such impairments1 for a continuous period of at least

12 months, no disability will be found. Id. Third, if the claimant’s severe impairments meet or equal the criteria of an impairment set forth in the Commissioner’s Listing of Impairments, the claimant will be found disabled. Id. If the fourth step is reached, the Commissioner considers its

assessment of the claimant’s residual functional capacity (RFC), and will find the claimant not disabled if he or she can still do past relevant work. Id. At the final step, the Commissioner reviews the claimant’s RFC, age,

education, and work experiences, and determines whether the claimant could adjust to other work. Id. The claimant bears the burden of proof throughout the first four steps, but the burden shifts to the Commissioner if the fifth step is reached. Preslar v. Sec’y of Health & Human Servs., 14

F.3d 1107, 1110 (6th Cir. 1994).

1 A severe impairment is one that “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1520(c). Applying this framework, the ALJ concluded that plaintiff was not disabled. At the first step, he found that plaintiff had not engaged in

substantial gainful activity since the alleged onset date of September 15, 2021. ECF No. 6-1, PageID.37. At the second step, he found that plaintiff had the severe impairments of psychosis, depression, degenerative disc

disease of the lumbar spine, and obesity. Id. Next, the ALJ concluded that none of plaintiff’s impairments, either alone or in combination, met or medically equaled the severity of a listed impairment. Id., PageID.37-38. Between the third and fourth steps, the ALJ found that plaintiff had

the RFC to perform a reduced range of light work2: except not climb ladders, ropes, or scaffolds; occasionally climb ramps/stairs, balance, stoop, kneel, crouch, and crawl; avoid exposure to unprotected heights; perform simple, routine, and repetitive tasks in an environment isolated from the public with occasional coworker and supervisor interaction. Id., PageID.38. At step four, the ALJ found that plaintiff could not perform his past relevant work. Id. at PageID.40. After considering plaintiff’s age, education, work experience, RFC, and the testimony of the VE, the ALJ determined at the final step that there were jobs in significant numbers that

2 Light work involves occasionally lifting or carrying 20 pounds at a time, frequently lifting or carrying ten pounds at a time, and standing or walking for six hours out of an eight-hour workday. 20 C.F.R. § 404.1567(b); Social Security Regulation 83-10. plaintiff could perform, including positions as a scrap sorter, folder, and inspector. Id. at PageID.41.

III. Analysis A. Under § 405(g), this Court’s review is limited to determining whether

the Commissioner’s decision is supported by substantial evidence3 and conformed with proper legal standards. Gentry v. Comm’r of Soc. Sec., 741 F.3d 708, 722 (6th Cir. 2014). Under the substantial-evidence standard, a court looks to an existing administrative record and asks whether it contains sufficient evidence to support the agency’s factual determinations. And whatever the meaning of substantial in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence, this Court has said, is more than a mere scintilla. It means—and means only—such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (cleaned up). The substantial-evidence standard does not permit the Court to independently weigh the evidence. Hatmaker v. Comm’r of Soc. Sec., 965 F. Supp. 2d 917, 930 (E.D. Tenn. 2013) (“The Court may not reweigh the evidence and substitute its own judgment for that of the Commissioner merely because

3 Only the evidence in the record below may be considered when determining whether the ALJ’s decision is supported by substantial evidence. Bass v. McMahon, 499 F.3d 506, 513 (6th Cir. 2007). substantial evidence exists in the record to support a different conclusion.”); see also Cutlip v. Sec’y of Health & Hum. Servs., 25 F.3d 284, 286 (6th Cir.

1994) (“If the Secretary’s decision is supported by substantial evidence, it must be affirmed even if the reviewing court would decide the matter differently, and even if substantial evidence also supports the opposite

conclusion.”).

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Related

Bass v. McMahon
499 F.3d 506 (Sixth Circuit, 2007)
Reed v. Secretary of Health and Human Services
804 F. Supp. 914 (E.D. Michigan, 1992)
Gentry v. Commissioner of Social Security
741 F.3d 708 (Sixth Circuit, 2014)
Essary v. Commissioner of Social Security
114 F. App'x 662 (Sixth Circuit, 2004)
Kornecky v. Commissioner of Social Security
167 F. App'x 496 (Sixth Circuit, 2006)
Watters v. Commissioner of Social Security Administration
530 F. App'x 419 (Sixth Circuit, 2013)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Kennedy v. Commissioner of Social Security
87 F. App'x 464 (Sixth Circuit, 2003)
Hatmaker v. Commissioner of Social Security
965 F. Supp. 2d 917 (E.D. Tennessee, 2013)

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