Heath v. Commissioner of Social Security

CourtDistrict Court, W.D. Kentucky
DecidedFebruary 26, 2025
Docket3:24-cv-00095
StatusUnknown

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

Bluebook
Heath v. Commissioner of Social Security, (W.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY LOUISVILLE DIVISION CIVIL ACTION NO. 3:24-CV-00095-RSE

Robin H. PLAINTIFF

VS.

MARTIN O’MALLEY, Commissioner of Social Security1 DEFENDANT

MEMORANDUM OPINION AND ORDER The Commissioner of Social Security denied Claimant Robin H.’s application for disability insurance benefits and supplemental security income benefits. Claimant presently seeks judicial review of the Commissioner’s denial pursuant to 42 U.S.C. § 405(g). Both Claimant (DN 13; DN 14) and the Commissioner (DN 16) have filed a Fact and Law Summary. Claimant did not file a reply brief. The Parties have consented, under 28 U.S.C. § 636(c) and Fed. R. Civ. P. 73, to the undersigned United States Magistrate Judge conducting all further proceedings in this case, including issuance of a memorandum opinion and entry of judgment, with direct review by the Sixth Circuit Court of Appeals in the event an appeal is filed. (DN 11). I. Background Robin H. (“Claimant”) applied for disability insurance benefits under Title II of Social Security Act and supplemental security income benefits under Title XVI of the Social Security Act on November 15, 2019. (Transcript (“Tr.”) 771). The applications alleged Claimant’s

1 Martin O’Malley became the Commissioner of Social Security on December 20, 2023. Pursuant to Federal Rule of Civil Procedure 25(d), Martin O’Malley is substituted for Kilolo Kijakazi as Defendant in this case. disability began on July 20, 20152 due to “Ptsd [sic], major [d]epression, anxiety, ocd [sic], bipolar, dvt [sic], bile reflux, migraines, add [sic], [and] nerve damage.” (Tr. 771-72, see Tr. 954, 958). Claimant’s applications were denied at the initial and reconsideration levels. (Tr. 841-55). At Claimant’s request, Administrative Law Judge Davida Isaacs (“ALJ Isaacs”) conducted a hearing in Campbellsville, Kentucky, on January 4, 2021. (Tr. 57-78). Claimant, who was not

represented, appeared by telephone.3 (Id.). An impartial vocational expert also participated in the hearing. (Id.). On August 30, 2021, ALJ Isaacs issued an unfavorable decision finding that Claimant was not disabled. (Tr. 811-25). Applying the five-step sequential evaluation process promulgated by the Commissioner, 20 C.F.R. § 404.1520(a), ALJ Isaacs determined that, while Claimant had severe impairments of post-traumatic stress disorder (“PTSD”), depression, anxiety, and attention deficit hyperactivity disorder (“ADHD”), she still retained the residual functional capacity (“RFC”) to perform medium work with no exertional or manipulative limitations but additional environmental and mental limitations. (Id.). ALJ Isaacs described Claimant’s migraines as a non-

severe impairment, explaining that “while the record support[s] that the claimant had a significant period of time after the alleged onset date during which she suffered from severe migraines, the evidence does not support that such migraines lasted for more than twelve months.” (Tr. 816 (emphasis removed)). Claimant filed a request for review with the Appeals Council, which was granted, and the Appeals Counsel issued an order remanding the claim back to ALJ Isaacs on September 7, 2022.

2 The Claimant’s Brief, the Commissioner’s Fact and Law Summary, and the ALJ decisions state the alleged disability began on January 30, 2016. (DN 13, at PageID # 4442; DN 16, at PageID # 4466; Tr. 15, 811; see Tr. 884, 935, 967, 979). This discrepancy is inconsequential to the case. Agency regulations preclude the receipt of SSI benefits for any month prior to that in which she filed her application. See 20 C.F.R. § 416.335. Accordingly, the period relevant of the determination of Claimant’s SSI claim falls between November 15, 2019, the date upon which she filed that claim, and May 11, 2023, the date of the ALJ’s final decision. Id. 3 The hearing was conducted telephonically because of the COVID-19 pandemic. (Tr. 59). (Tr. 831-34). The Appeals Counsel stated that “[r]emand is needed to explain the claimant’s ability to interact with others” and that “[f]urther explanation is needed” to state the parameters of Claimant’s limitation to “jobs not involving fast-pace [sic] tasks (as defined in the hearing).” (Tr. 833). On March 1, 2023, ALJ Isaacs convened a remand hearing in Campbellsville, Kentucky,

as contemplated by the Appeals Council’s remand order. (Tr. 35-49; see Tr. 834 (“[T]he Administrative Law Judge will take any further action needed to complete the administrative record and issue a decision.”)). Claimant attended the hearing by telephone with her non-attorney representative.4 (Tr. 37). An impartial vocational expert also participated in the hearing. (Id.). During the hearing, Claimant testified to the following. Since the previous hearing, her “migraines have gotten worse.” (Tr. 39). She “keep[s] trying different medications” but has experienced issues with refilling her prescriptions due to insurance. (Id.). A few of her medications make her tired, and a couple lower her blood pressure. (Tr. 42). As to the frequency of her migraines, Claimant stated “[t]hey’re technically every day, but the ones that are really, really bad that will put me in

the bedroom and in bed, are probably about three or four a week.” (Tr. 39). She claimed her migraines are triggered by “[a]nything bright,” loud sounds, “any type of screen” for longer than one hour, “a lot of caffeine,” and stress. (Tr. 39-40). Claimant testified that her migraines usually last anywhere from “a few hours to a few days.” (Tr. 40). As for help around the house, Claimant stated that her mother-in-law sometimes helps with tasks such as laundry and dishes. (Tr. 44). On May 11, 2023, ALJ Isaacs issued a second unfavorable decision concluding that Claimant was not disabled. (Tr. 15-27). In applying the five-step sequential analysis from 20 C.F.R. § 404.1520(a), ALJ Isaacs made the following findings. First, Claimant has not engaged in

4 This hearing was also held telephonically due to the Covid-19 pandemic with Claimant’s consent. (Tr. 37). substantial gainful activity since November 15, 2019, the application date. (Tr. 17). Second, Claimant has the following severe impairments: PTSD, depression, anxiety, ADHD, and migraines. (Tr. 18). Third, Claimant does not have an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments in 20 C.F.R. Part 404, Subpart P, Appendix 1. (Tr. 19). ALJ Isaacs specifically considered Listings 11.02, 12.04, 12.06,

12.11, and 12.15. (Id.). Fourth, Claimant has the RFC to perform medium work with the following exceptions: [S]he can never climb ladders, ropes, or scaffolds. She needs to avoid all exposure to large, moving machinery, vibration, and unprotected heights. She can have no interaction with the public and no more than occasional interaction with supervisors and co-workers. She can use judgment needed only to perform simple, routine tasks. She is limited to jobs not involving fast-paced tasks, as defined in the hearing as not assembly-line work or other work involving a quota that is hourly or more frequent.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Cite This Page — Counsel Stack

Bluebook (online)
Heath v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/heath-v-commissioner-of-social-security-kywd-2025.