Honeycutt v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedMarch 25, 2024
Docket1:23-cv-00101
StatusUnknown

This text of Honeycutt v. Commissioner of Social Security (Honeycutt 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
Honeycutt v. Commissioner of Social Security, (S.D. Ohio 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

AMANDA H.,1 : Case No. 1:23-cv-101 : Plaintiff, : Magistrate Judge Peter B. Silvain, Jr. : (by full consent of the parties) vs. : : COMMISSIONER OF THE SOCIAL : SECURITY ADMINISTRATION, : : Defendant. : : DECISION AND ENTRY

Plaintiff Amanda H. brings this case before the Court challenging the Social Security Administration’s denial of her application for Supplemental Security Income. She asserts that the Administrative Law Judge (ALJ) erred in considering the previous ALJ’s decision, evaluating her mental residual functional capacity, weighing the medical opinions, analyzing her subjective complaints, and posing a hypothetical to the vocational expert during the hearing. (Doc. #8). In the alternative, Plaintiff seeks a remand under Sentence Six of 42 U.S.C. § 405(g) for further proceedings on the ground that the administrative record contains new and material evidence. (Doc. #9). This case is before the Court upon Plaintiff’s Statement of Errors (Doc. #8), Plaintiff’s “Motion in Alternative to Remand Case under Sentence [Six] of 42 U.S.C. Section 405(g)”

1 The Committee on Court Administration and Case Management of the Judicial Conference of the United States has recommended that, due to significant privacy concerns in social security cases, federal courts should refer to plaintiffs only by their first names and last initials. See also S.D. Ohio General Rule 22-01. (“Motion to Remand”), the Commissioner’s Memorandum in Opposition (Doc. #14), Plaintiff’s Reply (Doc. #15), and the administrative record (Doc. #7). I. Background The Social Security Administration provides Supplemental Security Income to individuals who are under a “disability,” among other eligibility requirements. Bowen v. City of New York,

476 U.S. 467, 470 (1986); see 42 U.S.C. § 1382(a). The term “disability” encompasses “any medically determinable physical or mental impairment” that precludes an applicant from performing “substantial gainful activity.” 42 U.S.C. § 1382c(a)(3)(A); see Bowen, 476 U.S. at 469- 70. In the present case, Plaintiff protectively applied for benefits on January 26, 20212, alleging disability due to several impairments, including obsessive compulsive disorder, post-traumatic stress disorder, severe treatment resistant depression, morbid obesity, generalized anxiety disorder, sleep apnea, social anxiety disorder, and hypothyroidism. (Doc. #7-6, PageID #539). After Plaintiff’s application was denied initially and upon reconsideration, she requested and received a telephonic hearing before ALJ Anne Shaughnessy. Thereafter, the ALJ issued a written decision,

addressing each of the five sequential steps set forth in the Social Security Regulations. See 20 C.F.R. § 416.920. She reached the following main conclusions: Step 1: Plaintiff has not engaged in substantial gainful employment since January 26, 2021, the application date.

Step 2: She has the following severe impairments: obesity, obstructive sleep apnea, major depressive disorder, and generalized anxiety disorder.

2 Plaintiff previously filed for benefits on April 21, 2015. That application was denied by administrative decision on February 16, 2018. (Doc. #7-3, PageID #s 379-404). It does not appear that Plaintiff appealed that decision. 2 Step 3: She does not have an impairment or combination of impairments that meets or equals the severity of one in the Commissioner’s Listing of Impairments, 20 C.F.R. Part 404, Subpart P, Appendix 1.

Step 4: Her residual functional capacity, or the most she could do despite her impairments, see Howard v. Comm’r of Soc. Sec., 276 F.3d 235, 239 (6th Cir. 2002), consists of “light work … except she should avoid exposure to extreme heat, humidity, and wetness. She would need to avoid concentrated exposure to fumes, odors, dusts[,] and gases. She can have occasional interaction with coworkers and supervisors but no interaction with the public. She can adapt to routine changes in the work setting.”

She is unable to perform her past relevant work.

Step 5: Considering Plaintiff’s age, education, work experience, and residual functional capacity, there are jobs that exist in significant numbers in the national economy that she can perform.

(Doc. #7-2, PageID #s 41-49). Based on these findings, the ALJ concluded that Plaintiff was not under a benefits-qualifying disability since January 26, 2021, the date the application was filed. Id. at 49. The evidence of record is adequately summarized in the ALJ’s decision (Doc. #7-2, PageID #s 39-49), Plaintiff’s Statement of Errors (Doc. #8), the Commissioner’s Memorandum in Opposition (Doc. #14), and Plaintiff’s Reply (Doc. #15). To the extent that additional facts are relevant, they will be summarized in the discussion section below. II. Standard of Review Judicial review of an ALJ’s decision is limited to whether the ALJ’s findings are supported by substantial evidence and whether the ALJ applied the correct legal standards. Blakley v. Comm’r of Soc. Sec., 581 F.3d 399, 406 (6th Cir. 2009); see Bowen v. Comm’r of Soc. Sec., 478 F.3d 742, 745-46 (6th Cir. 2007). Substantial evidence is such “relevant evidence that a reasonable mind might accept as adequate to support a conclusion.” Gentry v. Comm’r of Soc. Sec., 741 F.3d 708, 3 722 (6th Cir. 2014) (citing Rogers v. Comm’r of Soc. Sec., 486 F.3d 234, 241 (6th Cir. 2007)). It is “less than a preponderance but more than a scintilla.” Id. The second judicial inquiry—reviewing the correctness of the ALJ’s legal analysis—may result in reversal even if the ALJ’s decision is supported by substantial evidence in the record. Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647, 651 (6th Cir. 2009). Under this review, “a decision

of the Commissioner will not be upheld where the [Social Security Administration] fails to follow its own regulations and where that error prejudices a claimant on the merits or deprives the claimant of a substantial right.” Bowen, 478 F.3d at 746 (citing Wilson v. Comm’r of Soc. Sec., 378 F.3d 541, 546-47 (6th Cir. 2004)). III. Discussion As noted above, Plaintiff has filed both a Statement of Errors and a Motion to Remand. In her Statement of Errors, she raises several assignments of errors, including that the ALJ erred by (1) applying Acquiescence Rulings 98-3(6) and 98-4(6) to the prior 2018 ALJ denial decision; (2) formulating her mental residual functional capacity determination; (3) weighing the medical source opinions; (4) evaluating Plaintiff’s subjective complaints; and (5) composing insufficient

hypothetical questions to the vocational expert.

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Related

Bowen v. City of New York
476 U.S. 467 (Supreme Court, 1986)
Bruce Coldiron v. Commissioner of Social Security
391 F. App'x 435 (Sixth Circuit, 2010)
Jimmie L. Howard v. Commissioner of Social Security
276 F.3d 235 (Sixth Circuit, 2002)
Gary Warner v. Commissioner of Social Security
375 F.3d 387 (Sixth Circuit, 2004)
Robert M. Wilson v. Commissioner of Social Security
378 F.3d 541 (Sixth Circuit, 2004)
David Bowen v. Commissioner of Social Security
478 F.3d 742 (Sixth Circuit, 2007)
Debra Rogers v. Commissioner of Social Security
486 F.3d 234 (Sixth Circuit, 2007)
Lynn Ulman v. Commissioner of Social Security
693 F.3d 709 (Sixth Circuit, 2012)
Justice v. Commissioner Social Security Administration
515 F. App'x 583 (Sixth Circuit, 2013)
Blakley v. Commissioner of Social Security
581 F.3d 399 (Sixth Circuit, 2009)
Jordan v. Commissioner of Social Security
548 F.3d 417 (Sixth Circuit, 2008)

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Honeycutt v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/honeycutt-v-commissioner-of-social-security-ohsd-2024.