Gardner v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedJune 21, 2022
Docket1:21-cv-00515
StatusUnknown

This text of Gardner v. Commissioner of Social Security (Gardner 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
Gardner v. Commissioner of Social Security, (S.D. Ohio 2022).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

DENITA G.,1 Case No. 1:21-cv-515 o/b/o D.T.J.J., MINOR Black, J. Plaintiff, Litkovitz, M.J.

vs.

COMMISSIONER OF REPORT AND SOCIAL SECURITY, RECOMMENDATION Defendant.

Plaintiff Denita G., on behalf of her minor daughter, D.T.J.J. (claimant), brings this action pursuant to 42 U.S.C. § 405(g) for judicial review of the final decision of the Commissioner of Social Security (Commissioner) that claimant’s disability ceased on May 13, 2019, and she no longer qualified for Supplemental Security Income (SSI) child benefits. This matter is before the Court on plaintiff’s Statement of Errors (Doc. 9), the Commissioner’s response, (Doc. 14), and plaintiff’s reply (Doc. 19). I. Procedural Background Plaintiff filed an application for child SSI benefits on claimant’s behalf in May 2012. (Tr. 185-90). In a July 25, 2012 determination, the Commissioner found claimant disabled due to speech and language delays that functionally equaled the criteria of a listing with an onset date of May 17, 2012. (Tr. 15, 18, 75-90). The Commissioner determined that claimant’s impairments continued to functionally equal the listings as of November 18, 2015. (Tr. 49). Following a continuing disability review, including reconsideration by a state agency disability hearing officer, the Commissioner determined that claimant’s disability ceased in May

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. 2019 because claimant had experienced medical improvement. (Tr. 67, 74, 91, 105-40). Plaintiff thereafter requested and received a de novo hearing of the case by Administrative Law Judge (ALJ) Christopher S. Tindale. Plaintiff appeared and testified at the ALJ hearing on July 13, 2020 via telephone. (Tr. 38-48). On September 10, 2020, the ALJ issued a decision finding that claimant’s disability ended as of May 13, 2019, and she had not become disabled again since that date. (Tr. 15-31). Plaintiff’s request for review by the Appeals Council was denied, making

the decision of the ALJ the final decision of the Commissioner. (Tr. 1-6). II. Analysis A. Legal Framework for Disability Determinations To qualify for SSI, plaintiff must file an application and be an “eligible individual” as defined in the Act. 42 U.S.C. § 1382(a); 20 C.F.R. § 416.202. Eligibility is dependent upon disability, income, and other financial resources. Id. An individual under the age of 18 is considered disabled for purposes of SSI “if that individual has a medically determinable physical or mental impairment, which results in marked and severe functional limitations, and 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. § 1382c(a)(3)(C)(i).

The Social Security regulations set forth a three-step sequential analysis for determining whether a child is disabled for purposes of children’s SSI benefits: 1. Is the child engaged in any substantial gainful activity? If so, benefits are denied.

2. Does the child have a medically severe impairment or combination of impairments? If not, benefits are denied.

3. Does the child’s impairment meet, medically equal, or functionally equal any in the Listing of Impairments, Appendix 1 of 20 C.F.R. Pt. 404, Subpart P, 20 C.F.R. § 416.924(a)? If so, benefits are granted. 2 20 C.F.R. § 416.924(a)-(d). An impairment which meets or medically equals the severity of a set of criteria for an impairment in the listings, or which functionally equals a listed impairment, causes marked and severe functional limitations. Id. at § 416.924(d). An individual has a “marked” limitation when the impairment “interferes seriously with [the] ability to independently initiate, sustain, or complete activities.” Id. at § 416.926a(e)(2)(i). A “marked” limitation is one that is “more than moderate” but “less than extreme.” Id. An “extreme” limitation exists when the impairment “interferes very seriously with [the] ability to independently initiate, sustain, or complete activities.” Id. at § 416.926a(e)(3)(i). Day-to-day functioning may be “very seriously limited” when only one activity is limited by the impairment or when several activities are limited by the

impairment’s cumulative effects. Id. If the child’s impairment meets, medically equals, or functionally equals an impairment in the listings, and if the impairment satisfies the Act’s duration requirement, then the child is considered disabled. Id. at § 416.924(d)(1). If both of these requirements are not satisfied, then the child is not considered disabled. Id. at § 416.924(d)(2). Using this three-step process, the Commissioner found claimant disabled as of May 17, 2012 because her impairments functionally equaled the listings. (Tr. 49, 75-90). Where, as here, a child has previously been found to be disabled under the Social Security regulations, continued eligibility for benefits must be reviewed periodically. Id. at § 416.994a(a). The Commissioner must first determine whether there has been medical improvement in the

child’s condition. If there has been no medical improvement, the child is found to still be disabled. Id. at § 416.994a(a)(1). If there has been medical improvement, the Commissioner 3 evaluates whether the child’s impairments still meet or equal the severity of the listed impairment that it met or equaled before; if they do, the child is found to still be disabled. Id. If the impairments no longer meet or equal the severity of the listed impairment, the agency proceeds to determine whether the child’s impairments meet or medically or functionally equal a listing. Id. In determining whether a child’s impairments functionally equals a listing, the adjudicator must assess the child’s functioning in six domains:

1. Acquiring and using information; 2. Attending and completing tasks; 3. Interacting and relating with others; 4. Moving about and manipulating objects; 5. Caring for yourself; and 6. Health and physical well-being. 20 C.F.R. § 416.926a(b)(1)(i)-(vi). To functionally equal a listing, an impairment(s) must result in “marked” limitations in two domains of functioning or an “extreme” limitation in one domain. Id. at § 416.926a(d). The relevant factors that will be considered in making this evaluation are (1) how well the child initiates and sustains activities, how much extra help she needs, and the effects

of structured or supportive settings; (2) how the child functions in school; and (3) the effects of the child’s medications or other treatment. Id. at § 416.926a(a)(1)-(3). B. The Administrative Law Judge’s Findings The ALJ applied the sequential evaluation process under the child disability standards and made the following findings of fact and conclusions of law:

4 1. The most recent favorable medical decision finding that the claimant continued to be disabled is the determination dated November 18, 2015. This is known as the “comparison point decision” or CPD.

2.

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