Hohman v. Commissioner of Social Security

CourtDistrict Court, M.D. Pennsylvania
DecidedSeptember 30, 2022
Docket3:21-cv-00856
StatusUnknown

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

Bluebook
Hohman v. Commissioner of Social Security, (M.D. Pa. 2022).

Opinion

UNITED STATES DISTRICT COURT MIDDLE DISTRICT OF PENNSYLVANIA

CHRISTOPHER HOHMAN,

Plaintiff, CIVIL ACTION NO. 3:21-cv-00856

v. (SAPORITO, M.J.)

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

MEMORANDUM In this matter, the plaintiff, Christopher Hohman, seeks judicial review of the final decision of the Commissioner of Social Security denying his application for disability insurance benefits, pursuant to 42 U.S.C. § 405(g). The matter has been referred to the undersigned United States magistrate judge on consent of the parties, pursuant to 28 U.S.C. § 636(c) and Fed. R. Civ. P. 73. I. BACKGROUND On May 30, 2019, Hohman protectively filed a claim for disability insurance benefits, asserting a disability onset date of November 10, 2016. The claim was initially denied by state agency reviewers on November 1, 2019, and upon reconsideration on April 24, 2020. The plaintiff then requested an administrative hearing.

A hearing was subsequently held on August 17, 2020, before an administrative law judge, Michelle Wolfe (the “ALJ”). In addition to the plaintiff himself, the ALJ received testimony from an impartial

vocational expert, Donna Nealon. The plaintiff was represented by counsel at the hearing. On September 10, 2020, the ALJ denied Hohman’s application for

benefits in a written decision. The ALJ followed the familiar five-step sequential evaluation process in determining that Hohman was not disabled under the Social Security Act. See generally Myers v. Berryhill,

373 F. Supp. 3d 528, 534 (M.D. Pa. 2019) (describing the five-step sequential evaluation process). At step one, the ALJ found that Hohman had not engaged in substantial gainful activity from March 12, 2019,

through his date last insured of December 31, 2019. At step two, the ALJ found that Hohman had the severe impairments of: degenerative disc disease of thoracic and lumbar spine; status post-cervical fusion; large

fiber polyneuropathy, diabetes mellitus, obesity, coronary artery disease, and hypertrophic cardiomyopathy. At step three, the ALJ found that Hohman did not have an impairment or combination of impairments that meets or medically equals the severity of an impairment listed in 20

C.F.R. Part 404, Subpart P, Appendix 1 (eff. Apr. 1, 2018).1 Between steps three and four of the sequential evaluation process, the ALJ assessed Hohman’s residual functional capacity (“RFC”). See

generally id. at 534 n.4 (defining RFC). After evaluating the relevant evidence of record, the ALJ found that Hohman had the RFC to perform “light work” as defined in 20 C.F.R. § 404.1567(b),2 with the following

limitations: The claimant must be afforded a sit/stand option with each interval being maximum of 30 minutes each time, but not off task when transferring. The claimant can frequently push/pull with the upper and lower extremities. The claimant can frequently kneel and crouch. The claimant can occasionally balance, stoop, crawl, and climb, but never on ladders, ropes, or scaffolds. The claimant is limited to frequent exposure to temperature extremes of cold, wetness, humidity, and vibrations. The claimant requires a cane for ambulation at times.

1 We note that the agency’s list of musculoskeletal disorders was extensively revised effective April 2, 2021, after this plaintiff’s application for disability and disability benefits was adjudicated by the agency. See generally Revised Medical Criteria for Evaluating Musculoskeletal Disorders, 85 Fed. Reg. 78164 (Dec. 3, 2020) (to be codified at 20 C.F.R. pt. 404, subpt. P, app. 1). 2 The Social Security regulations define “light work” as a job that “involves lifting no more than 20 pounds at a time with frequent lifting or carrying of objects weighing up to 10 pounds.” 20 C.F.R. § 404.1567(b). (Tr. 14.)

In making these factual findings regarding Hohman’s RFC, the ALJ considered his symptoms and the extent to which they could reasonably be accepted as consistent with the objective medical evidence and other

evidence of record. See generally 20 C.F.R. § 404.1529; Soc. Sec. Ruling 16-3p, 2017 WL 5180304 (revised Oct. 25, 2017). The ALJ also considered and articulated how persuasive she found the medical opinions and prior

administrative medical findings of record. See generally 20 C.F.R. § 404.1520c. At step four, based on this RFC and on testimony by the vocational

expert, the ALJ concluded that Hohman was capable of performing his past relevant work as an emergency service coordinator/dispatcher, DOT # 249.167-014. This work did not require the performance of work-related

activities precluded by the claimant’s residual functional capacity. Based on this finding, the ALJ concluded that Hohman was not disabled for Social Security purposes.

The plaintiff sought further administrative review of his claim by the Appeals Council, but his request was denied on March 10, 2021, making the ALJ’s September 2020 decision the final decision of the Commissioner subject to judicial review by this court.

Hohman timely filed his complaint in this court on May 11, 2021. The Commissioner has filed an answer to the complaint, together with a certified copy of the administrative record. Both parties have filed their

briefs, and this matter is now ripe for decision. II. DISCUSSION Under the Social Security Act, the question before this Court is not whether Hohman is disabled, but whether the Commissioner’s finding

that he is not disabled is supported by substantial evidence and was reached based upon a correct application of the relevant law. See

generally 42 U.S.C. § 405(g)(sentence five); Myers, 373 F. Supp. 3d at 533 (describing standard of judicial review for social security disability insurance benefits and supplemental security income administrative

decisions). Hohman asserts on appeal that the ALJ’s decision is not supported by substantial evidence because: (1) the ALJ failed to properly evaluate

a medical opinion by Hohman’s treating physician; (2) the ALJ failed to properly consider Hohman’s subjective allegations regarding his symptoms; (3) the ALJ erred at step three in finding that Hohman did not have an impairment or combination of impairments that met the

criteria of Listed Impairment 1.04, concerning disorders of the spine; and (4) the ALJ erred at step three in finding that Hohman did not have an impairment or combination of impairments that met the criteria of Listed

Impairment 11.14, concerning peripheral neuropathy.3 A. Medical Opinions and Prior Administrative Findings The plaintiff contends that the ALJ’s decision is not supported by substantial evidence because the ALJ erred in her evaluation of

conflicting medical opinions and prior administrative findings presented in the administrative proceedings below. As a preface, we note the well-

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