Crawley v. Commissioner of Social Security

CourtDistrict Court, N.D. Ohio
DecidedMay 20, 2025
Docket1:24-cv-01760
StatusUnknown

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

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Crawley v. Commissioner of Social Security, (N.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

CASE NO. 1:24-cv-1760 PAUL E. CRAWLEY, JR., DISTRICT JUDGE Plaintiff, BRIDGET MEEHAN BRENNAN

vs. MAGISTRATE JUDGE JAMES E. GRIMES JR. COMMISSIONER OF SOCIAL SECURITY, REPORT & Defendant. RECOMMENDATION

Plaintiff Paul E. Crawley, Jr., filed a Complaint against the Commissioner of Social Security seeking judicial review of a decision denying his application for disability insurance and social security income benefits. Doc. 1. This Court has jurisdiction under 42 U.S.C. §§ 405(g) and 1383(c). The Court referred this matter to a Magistrate Judge under Local Rule 72.2(b)(1) for the preparation of a Report and Recommendation. Following review, and for the reasons stated below, I recommend that the District Court affirm the Commissioner’s decision. Procedural Background

Previous application. In July 2016, Crawley filed an application for disability insurance benefits alleging a disability onset date in September 2015.1 Tr. 88. His application was denied initially and on reconsideration. Id. In May 2017, Crawley requested a hearing before an administrative law judge (ALJ). Id. In June 2018, ALJ Traci Hixson held a hearing. Id. In November

2018, ALJ Hixson issued a decision denying Crawley’s application. Tr. 85–108. In December 2019, the Appeals Council affirmed the ALJ’s November 2018 decision. Tr. 109–114. Because Crawley did not further appeal, the ALJ’s November 2018 decision became the final decision of the Commissioner as to his July 2016 application. Current application. In March 2020, Crawley filed applications for

disability insurance and supplemental security income benefits alleging a disability beginning in September 2015. Tr. 218–228. In pertinent part, Crawley alleged that he was disabled and limited in his ability work, due to: back issues, kidney problems, gout, knee issues, arthritis, diabetes, and neck problems. Tr. 252. The Commissioner denied Crawley’s application initially and on reconsideration. See Tr. 159, 170. In January 2021, Crawley requested a hearing. Tr. 177. In October 2021,

ALJ Catherine Ma held a telephonic hearing. Tr. 47. Crawley appeared, testified, and was represented by counsel at the hearing. Tr. 47. Qualified vocational expect Brett Salkin also testified. Tr. 74. In December 2021, ALJ

1 “Once a finding of disability is made, the [agency] must determine the onset date of the disability.” McClanahan v. Comm’r of Soc. Sec., 193 F. App’x 422, 425 (6th Cir. 2006). Ma issued a written decision, in which she found that Crawley was not entitled to benefits. Tr. 12–36. In January 2022, Crawley appealed the ALJ’s decision to the Appeals

Council. Tr. 215. In February 2023, the Appeals Council denied Crawley’s appeal. Tr. 1. In April 2023, Crawley filed a Complaint against the Commissioner, docketed as case no. 1:23-cv-799, challenging the ALJ’s decision. In September 2023, this Court remanded, based on the parties’ stipulation, for “further administrative proceedings pursuant to Sentence Four of Section 205 of the Social Security Act, 42 U.S.C. § 405(g).” Tr. 1098. In

December 2023, the Appeals Council issued an Order vacating ALJ Ma’s December 2021 decision, finding that “the hearing decision does not contain an adequate evaluation of the medical source opinions from Jonathan Belding, M.D., and Joseph Konieczny, Ph.D.” See Tr. 1101 The Appeals Council also directed the ALJ to consider the following on remand: • Give further consideration to the medical source opinion(s) and prior administrative medical findings pursuant to the provisions of 20 CFR 404.1520c and 416.920c. As appropriate, the Administrative Law Judge may request the medical sources provide additional evidence and/or further clarification of the opinions (20 CFR 404.1520b and 416.920b). The Administrative Law Judge may enlist the aid and cooperation of the claimant's representative in developing evidence from the claimant's medical sources.

• Give further consideration to the claimant's maximum residual functional capacity and provide appropriate rationale with specific references to evidence of record in support of the assessed limitations (20 CFR 404.1545 and 416.945 and Social Security Ruling 85-16 and 96-8p).

• If warranted by the expanded record, obtain supplemental evidence from a vocational expert to clarify the effect of the assessed limitations on the claimant's occupational base (Social Security Ruling 83-14). The hypothetical questions should reflect the specific capacity/limitations established by the record as a whole. The Administrative Law Judge will ask the vocational expert to identify examples of appropriate jobs and to state the incidence of such jobs in the national economy (20 CFR 404.1566 and 416.966). Further, before relying on the vocational expert evidence the Administrative Law Judge will identify and resolve any conflicts between the occupational evidence provided by the vocational expert and information in the Dictionary of Occupational Titles (DOT) and its companion publication, the Selected Characteristics of Occupations (Social Security Ruling 00-4p). Tr. 1102. In April 2024, ALJ Ma held a telephonic hearing. Tr. 1035–1066. During the hearing, Crawley‘s counsel amended Crawley’s alleged onset date to November 10, 2018. Tr. 17. In July 2024, the ALJ issued a partially favorable decision, Tr. 999–1023, which Crawley now appeals. Crawley timely filed this action in October 2024. Doc. 1. In it, he asserts three issues: 1. The ALJ erred when she applied the wrong standard of review when she adopted the residual functional capacity (RFC)2 of the prior Administrative Law Judge.

2. The ALJ erroneously failed to comply with the Order of Remand when she improperly assessed the opinions of the treating and examining sources.

3. The ALJ’s finding that Plaintiff could perform work at the light level of exertion and did not require the use of a cane for balance was not supported by substantial evidence and was contrary to Social Security Ruling 96-9p.

Doc. 7, at 1. Evidence3 Personal, Educational, and Vocational Evidence Crawley was born in March 1969, making him 46 on the original alleged onset date in 2015 and 49 on the amended alleged onset date in 2018. Tr. 248. Crawley graduated from high school and completed a “computerized machinery program.” Tr. 253. Medical Evidence In June 2018, Dr. Cherrica Davis, of Lake Health Physician Group, noted Crawley’s sciatic nerve pain, which had caused him to twice visit an emergency room in the interim since his last visit to the practice. Tr. 431.

2 An RFC is an “assessment of” a claimant’s ability to work, taking his or her “limitations … into account.” Howard v. Comm’r of Soc. Sec., 276 F.3d 235, 239 (6th Circ. 2002). Essentially, it is the Social Security Administration’s “description of what the claimant ‘can and cannot do.’” Webb v. Comm’r of Soc. Sec., 368 F.3d 629, 631 (6th Cir.

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