Crase v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedSeptember 5, 2024
Docket2:23-cv-01469
StatusUnknown

This text of Crase v. Commissioner of Social Security (Crase 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
Crase v. Commissioner of Social Security, (S.D. Ohio 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION AT COLUMBUS

KIMBERLY C.,1 : Case No. 2:23-cv-01469 : Plaintiff, : Magistrate Judge Caroline H. Gentry : (by full consent of the parties) vs. : : COMMISSIONER OF THE SOCIAL : SECURITY ADMINISTRATION, : Defendant. :

DECISION AND ORDER

Plaintiff filed an application for Disability Insurance Benefits in March 2018. Plaintiff’s claim was denied initially and upon reconsideration. After a hearing at Plaintiff’s request, an Administrative Law Judge (ALJ) concluded that Plaintiff was not eligible for benefits because she was not under a “disability” as defined in the Social Security Act. The Appeals Council remanded the decision for further consideration of several issues. Another ALJ held a hearing and again concluded that Plaintiff was not under a “disability” as defined in the Social Security Act. The Appeals Council denied Plaintiff’s request for review of that decision, and Plaintiff filed an action with this Court.2 The Court remanded the case to the Commissioner under Sentence Four of 42

1 See S.D. Ohio General Order 22-01 (“The Committee on Court Administration and Case Management of the Judicial Conference of the United States has recommended that due to significant privacy concerns in social security cases federal courts should refer to claimants only by their first names and last initials.”). 2 Assigned to District Judge Michael H. Watson, Case Number 2:21-cv-00595. U.S.C. § 405(g), pursuant to a joint stipulation by the parties. The Appeals Council remanded the case pursuant to the District Court’s order. The same ALJ held a hearing

and issued the third unfavorable decision in this case—again concluding that Plaintiff was not under a “disability” as defined in the Social Security Act. The Appeals Council denied Plaintiff’s request for review of that decision, and Plaintiff subsequently filed what is now her second action with this Court. Plaintiff seeks an order remanding this matter to the Commissioner for the award of benefits or, in the alternative, for further proceedings. The Commissioner asks the

Court to affirm the non-disability decision. For the reasons set forth below, this Court REVERSES the Commissioner’s decision and REMANDS for an immediate award of benefits. I. BACKGROUND Plaintiff asserts that she has been under a disability since March 1, 2018. At that

time, she was sixty-one years old. Accordingly, Plaintiff was considered “closely approaching retirement age” under Social Security Regulations. See 20 C.F.R. § 404.1563(e). Plaintiff has a “high school education and above.” See 20 C.F.R. § 404.1564(b)(4). The evidence in the Administrative Record (“AR,” Doc. No. 6) is summarized in

the ALJ’s decision (“Decision,” Doc. No. 6-9 at PageID 1080-1108), Plaintiff’s Statement of Errors (“SE,” Doc. No. 7), the Commissioner’s Memorandum in Opposition (“Mem. In Opp.,” Doc. No. 8), Plaintiff’s Reply Memorandum (“Reply,” Doc. No. 9), and Plaintiff’s Notice of Additional Authority (“Notice,” Doc. No. 10). Rather than repeat these summaries, the Court will discuss the pertinent evidence in its analysis below.

II. STANDARD OF REVIEW The Social Security Administration provides Disability Insurance Benefits to individuals who are under a “disability,” among other eligibility requirements. Bowen v. City of New York, 476 U.S. 467, 470 (1986); see 42 U.S.C. §§ 402, 423(a)(1), 1382(a). The term “disability” means “the inability to do any substantial gainful activity by reason of any medically determinable physical or mental impairment which . . . has lasted or can

be expected to last for a continuous period of not less than 12 months.” 20 C.F.R. § 404.1505(a). This Court’s review of an ALJ’s unfavorable decision is limited to two inquiries: “[W]hether the ALJ applied the correct legal standards and whether the findings of the ALJ are supported by substantial evidence.” Blakley v. Comm’r of Soc. Sec., 581 F.3d

399, 406 (6th Cir. 2009); see 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.”). “Unless the ALJ has failed to apply the correct legal standards or has made findings of fact unsupported by substantial evidence,” this Court must affirm the ALJ’s decision. Emard v. Comm’r of Soc. Sec., 953 F.3d 844, 849 (6th Cir. 2020). Thus, the Court “may

not try the case de novo, nor resolve conflicts in evidence, nor decide questions of credibility.” Id. “Under the substantial-evidence standard, a court looks to an existing administrative record and asks whether it contains ‘sufficien[t] evidence’ to support the agency’s factual determinations.” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (citation omitted). This limited standard of review does not permit the Court to weigh the

evidence and decide whether the preponderance of the evidence supports a different conclusion. Instead, the Court is confined to determining whether the ALJ’s decision is supported by substantial evidence, which “means—and means only—‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Id. (citation omitted). This standard “presupposes that there is a zone of choice within which the decisionmakers can go either way, without interference by the courts.” Mullen v.

Bowen, 800 F.2d 535, 545 (6th Cir. 1986). Thus, the Court may be required to affirm the ALJ’s decision even if substantial evidence in the record supports the opposite conclusion. Key v. Callahan, 109 F.3d 270, 273 (6th Cir.1997). The other line of judicial inquiry—reviewing the correctness of the ALJ’s legal criteria—may result in reversal even when the record contains substantial evidence

supporting the ALJ’s factual findings. Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647, 651 (6th Cir. 2009). “[E]ven if supported by substantial evidence, ‘a decision of the Commissioner will not be upheld where the SSA fails to follow its own regulations and where that error prejudices a claimant on the merits or deprives the claimant of a substantial right.’” Id. (citations omitted). Such an error of law will require reversal even

if “the outcome on remand is unlikely to be different.” Cardew v. Comm’r of Soc. Sec., 896 F.3d 742, 746 (6th Cir. 2018) (internal quotations and citations omitted). III. FACTS A. The ALJ’s Factual Findings

The ALJ was tasked with evaluating the evidence related to Plaintiff’s application for benefits. In doing so, the ALJ considered each of the five sequential steps set forth in the Social Security Regulations. See 20 C.F.R. § 404.1520.

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Related

Bowen v. City of New York
476 U.S. 467 (Supreme Court, 1986)
Jimmie L. Howard v. Commissioner of Social Security
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Renstrom v. Astrue
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Blakley v. Commissioner of Social Security
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Fleischer v. Astrue
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Melkonyan v. Sullivan
501 U.S. 89 (Supreme Court, 1991)
Simons v. Comm Social Security
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Doris Poe v. Commissioner of Social Security
342 F. App'x 149 (Sixth Circuit, 2009)
Phillip Stacey v. Commissioner of Social Security
451 F. App'x 517 (Sixth Circuit, 2011)
Bradley Cardew v. Comm'r of Soc. Sec.
896 F.3d 742 (Sixth Circuit, 2018)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Jeffery Emard v. Comm'r of Soc. Sec.
953 F.3d 844 (Sixth Circuit, 2020)

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Crase v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crase-v-commissioner-of-social-security-ohsd-2024.