Emily K. M. v. Commissioner of Social Security

District Court, S.D. Ohio·Decided June 29, 2026·No. 2:25-cv-01195·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

EMILY K. M.,

Plaintiff,

v. Civil Action 2:25-cv-1195 Judge Sarah D. Morrison Magistrate Judge Chelsey M. Vascura COMMISSIONER OF SOCIAL SECURITY,

Defendant.

REPORT AND RECOMMENDATION Plaintiff, Emily K. M. (“Plaintiff”), brings this action under 42 U.S.C. § 405(g) for review of a final decision of the Commissioner of Social Security (“Commissioner”) denying her applications for a period of disability and disability insurance benefits (“DIB”) and supplemental security income benefits (“SSI”). This matter is before the undersigned for a Report and Recommendation on Plaintiff’s Statement of Errors (ECF No. 13), the Commissioner’s Memorandum in Opposition (ECF No. 14), and the administrative record (ECF No. 8). For the reasons that follow, it is RECOMMENDED that Plaintiff’s Statement of Errors be OVERRULED and that the Commissioner’s decision be AFFIRMED. I. BACKGROUND Plaintiff filed her DIB and SSI applications in July 2022, alleging disability beginning January 26, 2021. (R. at 255–56, 257–63.) After those applications were denied initially and on reconsideration, an Administrative Law Judge (“ALJ”) held a telephonic hearing on December 20, 2024, at which Plaintiff, who was represented by council, and a vocational expert (“VE”) appeared and testified. (Id. at 72–102.) At the hearing, Plaintiff’s counsel asked the ALJ to admit into the record an Appeals Council decision from an unrelated case that defined the term “superficial interaction.”1 (Id. at 76–77.) Counsel acknowledged that the ALJ was not bound by that decision but asked “that it be

made part of the file so that . . . it provide[d] some basis for . . . the definition that [he would use] in some hypotheticals to the vocational witness.” (Id. at 77.) The ALJ indicated that he would take the request “under consideration” but declined to mark the Appeals Council decision as an exhibit at that time. (Id.) On February 10, 2026, the ALJ issued an unfavorable determination. (Id. at 44–67.) It became final on August 14, 2025, when the Appeals Council declined review. (Id. at 1–6.) Plaintiff seeks judicial review of that unfavorable determination. She contends that the ALJ committed reversible error by failing to make the Appeals Council decision part of the record given that a state agency reviewer found that she was limited to superficial interactions.

(Pl.’s Statement of Errors 6–11, ECF No. 13.) The Commissioner correctly contends that this contention lacks merit. (Def.’s Mem. in Opp’n 4–9, ECF No. 14.)

1 The July 27, 2022 Appeals Council decision in an unrelated case provided as follows:

‘[S]uperficial interaction’ is a term that is readily defined, easily understood and applicable to a work setting, as it speaks to the depth, kind and quality of social interaction, and indicates that the claimant could not have sustained more than shallow or cursory interactions with others, i.e., coworkes, the general public, and/or supervisors. The term is distinguishable and distinct from “occasional” which describes the frequency of interactions with others and how much interaction the claimant could tolerate on a sustained basis.’”

(Exhibit, Pl.’s Statement of Errors 4–5, ECF No. 13–1, PageID #558–59.) II. THE ALJ’S DECISION The ALJ issued the unfavorable determination on February 10, 2025. (R. at 44–67.) The ALJ initially determined that Plaintiff met the insured status requirements through March 31, 2026. (Id. at 50.) At step one of the sequential evaluation process,2 the ALJ determined that Plaintiff had not engaged in substantial gainful activity since her January 26, 2021 alleged

disability onset date. (Id.) At step two, the ALJ determined that Plaintiff had the following severe medically determinable impairments: anxiety disorder; major depressive disorder; polysubstance abuse disorder; post-traumatic stress disorder; peripheral artery disease; lupus; Sjogren’s syndrome; a history of right ankle fractures – status/post ORIF; lumbar spondylosis; and edema of the bilateral lower extremities. (Id.) At step three, the ALJ determined that Plaintiff did not

2 Social Security regulations require ALJs to resolve a disability claim through a five-step sequential evaluation of the evidence. See 20 C.F.R. § 404.1520(a)(4). Although a dispositive finding at any step terminates the ALJ’s review, see Colvin v. Barnhart, 475 F.3d 727, 730 (6th Cir. 2007), if fully considered, the sequential review considers and answers five questions:

1. Is the claimant engaged in substantial gainful activity?

2. Does the claimant suffer from one or more severe impairments?

3. Does the claimant’s severe impairment, alone or in combination with other impairments, meet or equal the criteria of an impairment set forth in the Commissioner’s Listing of Impairments, 20 C.F.R. Subpart P, Appendix 1?

4. Considering the claimant’s residual functional capacity, can the claimant perform his or her past relevant work?

5. Considering the claimant’s age, education, past work experience, and residual functional capacity, can the claimant perform other work available in the national economy?

See 20 C.F.R. § 404.1520(a)(4); see also Henley v. Astrue, 573 F.3d 263, 264 (6th Cir. 2009); Foster v. Halter, 279 F.3d 348, 354 (6th Cir. 2001). have an impairment or combination of impairments that met or medically equaled one of the listed impairments described in 20 C.F.R. Part 404, Subpart P, Appendix 1. (Id. at 51.) The ALJ then set forth Plaintiff’s residual functional capacity (“RFC”)3 as follows:

After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform sedentary work as defined in 20 CFR 404.1567(a) and 416.967(a), except she should avoid climbing ladders, ropes, or scaffolds; she could occasionally climb ramps and stairs; she could occasionally stoop, kneel, crouch, and crawl; she should avoid all exposure to hazards; she could occasionally interact with the public, coworkers, and supervisors, where all communications are limited to the straightforward exchange of information without negotiation, persuasion or conflict resolution; and she could deal with occasional changes in a routine work setting.

(Id. at 53.)

At step four, the ALJ relied on the VE’s testimony and determined that Plaintiff could not perform her past relevant work. (Id. at 59.) At step five, the ALJ again relied on the VE’s testimony and determined that considering Plaintiff’s age, education, work experience, and RFC, there were jobs that existed in significant numbers in the national economy that she could perform, including the representative jobs of food and beverage order clerk, document preparer, and assembler. (Id. at 61.) The ALJ therefore determined that Plaintiff was not disabled within the meaning of the Social Security Act during the relevant time frame. (Id. at 62.) III.

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Emily K. M. v. Commissioner of Social Security, (S.D. Ohio 2026).

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