Gallagher v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedJanuary 14, 2025
Docket3:24-cv-00025
StatusUnknown

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

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT DAYTON

DARRELL G.1, Case No. 3:24-cv-025 Plaintiff, Rose, J. Litkovitz, MJ. vs.

COMMISSIONER OF REPORT AND SOCIAL SECURITY, RECOMMENDATION Defendant. Plaintiff Darrell G. brings this action under 42 U.S.C. § 405(g) for judicial review of the final decision of the Commissioner of Social Security (Commissioner) denying plaintiff’s application for disability insurance benefits (DIB). This matter is before the United States Magistrate Judge for a Report and Recommendation on plaintiff’s Statement of Errors (Doc. 7), the Commissioner’s response in opposition (Doc. 9), and plaintiff’s reply (Doc. 10). I. Procedural Background On January 4, 2022, plaintiff protectively filed an application for DIB alleging disability beginning March 31, 2019, due to a back injury, nerve pain, depression, and leg and foot pain due to a back injury. (Tr. 175-81, 233). Plaintiff’s insured status lapsed on March 31, 2019, the same date as his alleged onset date. His application was denied initially and upon reconsideration. Plaintiff, through counsel, requested and was granted a de novo hearing before administrative law judge (ALJ) Nicholas J. Schwalbach. Plaintiff and a vocational expert (VE) appeared telephonically and testified at the ALJ hearing on January 31, 2023. (Tr. 33-64). On March 9, 2023, the ALJ issued a decision denying plaintiff’s application. (Tr. 17-32). The Appeals

1 Pursuant to General Order 22-01, due to significant privacy concerns in social security cases, any opinion, order, judgment, or other disposition in social security cases in the Southern District of Ohio shall refer to plaintiffs only by their first names and last initials. Council denied plaintiff’s request for review, making the ALJ’s decision the final decision of the Commissioner for purposes of judicial review. (Tr. 1-7). II. Analysis A. Legal Framework for Disability Determinations

To qualify for disability benefits, a claimant must suffer from a medically determinable physical or mental impairment that can be expected to result in death or that 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). The impairment must render the claimant unable to engage in the work previously performed or in any other substantial gainful employment that exists in the national economy. 42 U.S.C. § 423(d)(2). Regulations promulgated by the Commissioner establish a five-step sequential evaluation process for disability determinations: 1) If the claimant is doing substantial gainful activity, the claimant is not disabled.

2) If the claimant does not have a severe medically determinable physical or mental impairment – i.e., an impairment that significantly limits his or her physical or mental ability to do basic work activities – the claimant is not disabled.

3) If the claimant has a severe impairment(s) that meets or equals one of the listings in Appendix 1 to Subpart P of the regulations and meets the duration requirement, the claimant is disabled.

4) If the claimant’s impairment does not prevent him or her from doing his or her past relevant work, the claimant is not disabled.

5) If the claimant can make an adjustment to other work, the claimant is not disabled. If the claimant cannot make an adjustment to other work, the claimant is disabled.

Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647, 652 (6th Cir. 2009) (citing 20 C.F.R. §§ 404.1520(a)(4)(i)-(v), 404.1520(b)-(g)). The claimant has the burden of proof at the first four steps of the sequential evaluation process. Id.; Wilson v. Comm’r of Soc. Sec., 378 F.3d 541, 548 (6th Cir. 2004). Once the claimant establishes a prima facie case by showing an inability to perform the relevant previous employment, the burden shifts to the Commissioner to show that the claimant can perform other substantial gainful employment and that such employment exists in the national economy. Rabbers, 582 F.3d at 652; Harmon v. Apfel, 168 F.3d 289, 291 (6th Cir.

1999). B. The Administrative Law Judge’s Findings The ALJ applied the sequential evaluation process and made the following findings of fact and conclusions of law: 1. The [plaintiff] last met the insured status requirements of the Social Security Act on March 31, 2019.

2. The [plaintiff] did not engage in substantial gainful activity on March 31, 2019 (20 CFR 404.1571 et seq).

3. Through the date last insured, the [plaintiff] had the following severe impairment: [l]umbar degenerative disc disease, status post laminectomy (20 CFR 404.1520(c)).

4. Through the date last insured, the [plaintiff] did not have an impairment or combination of impairments that met or medically equaled the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1 (20 CFR 404.1520(d), 404.1525 and 404.1526).

5. Through the date last insured, the [plaintiff] had the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b), with the following limitations: no more than frequent climbing of ramps/stairs, kneeling, crouching, crawling, and no more than frequent pushing/pulling/operating foot controls with the right lower extremity; no more than occasional stooping and climbing ladders, ropes, and scaffolds; and no concentrated exposure to unprotected heights or dangerous machinery.

6. Through the date last insured, the [plaintiff] was unable to perform past relevant work (20 CFR 404.1565).2

2 Plaintiff’s past relevant work was a composite job consisting of a building repairer, a skilled, medium position; and a contractor, a skilled, light position. (Tr. 25, 59-60). 7. The [plaintiff] was born [in]… 1965. Therefore, he was 54 years old 2 months old, and defined as an individual closely approaching advanced age, on the date last insured (20 CFR 404.1563).

8. The [plaintiff] completed a high school education (20 CFR 404.1564).

9. Transferability of job skills is not material to the determination of disability because using the Medical-Vocational Rules as a framework supports a finding that the [plaintiff] is “not disabled,” whether or not the [plaintiff] has transferable job skills (See SSR 82-41 and 20 CFR Part 404, Subpart P, Appendix 2).

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