Horton v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedMarch 18, 2024
Docket2:23-cv-00914
StatusUnknown

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

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

ROBERT H.,1 : : Case No. 2:23-cv-914 Plaintiff, : : Chief Judge Algenon L. Marbley v. : : Magistrate Judge Elizabeth P. Deavers COMMISSIONER OF SOCIAL : SECURITY, : : Defendant. :

OPINION & ORDER This matter comes before this Court on Plaintiff’s Objection (ECF No. 14) to the Magistrate Judge’s January 9, 2024, Report and Recommendation (ECF No. 13), which recommended that Plaintiff’s Statement of Errors (ECF No. 10) be overruled and that the Commissioner’s decision be affirmed. This Court hereby ADOPTS the Report and Recommendation (ECF No. 13) in its entirety based on an independent consideration of the analysis therein and OVERRULES Plaintiff’s Statement of Errors. (ECF No. 10). I. BACKGROUND Plaintiff, Robert H., filed an application for Title XVI Supplemental Security Income on June 5, 2020, alleging that he had been disabled since July 27, 1995, due to a major depression. (R. at 419-25, 441). Plaintiff was later in a motor vehicle accident, after which he reported several physical impairments. (R. at 158). Plaintiff’s application was denied and subsequently denied upon reconsideration. (R. at 290-311). Plaintiff, represented by counsel, appeared and testified before the Administrative Law Judge Jeffrey Hartranft (the “ALJ”) on July 14, 2022. (R. at 153-75). On

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. September 26, 2022, the ALJ found that Plaintiff was not “disabled” within the meaning of the Social Security Act. (R. at 100-22). The Appeals Council denied Plaintiff’s request for review and accepted the ALJ’s decision as the Commissioner’s final decision. (R. at 1-7). Plaintiff timely filed an action for review by this Court. (ECF No. 1). Following the five-step sequential analysis required by 20 C.F.R. § 404.1520(a)(4),2 the

ALJ found that Plaintiff was not disabled within the meaning of the Social Security Act. (R. at 100-22). While the ALJ recognized that Plaintiff had severe mental and physical impairments, he ultimately concluded that they did not meet the level of medical severity required under Part B of Appendix I to Subpart P, 20 C.F.R. Part 404 to find Plaintiff disabled. (Id.). The ALJ explained that:

[Plaintiff] has the residual functional capacity to perform medium work as defined in 20 CFR 416.967(c) except [Plaintiff] could not climb ladders, ropes, or scaffolds. He would be capable of frequent reaching but no overhead reaching with his left arm. Mentally, he would be capable of simple routine and repetitive tasks involving only simple work-related

2 Although a dispositive finding at any step terminates the ALJ’s review, see Colvin v. Barnhart, 475 F.3d 727, 730 (6th Cir. 2007), the five step sequential steps are as follows: i. At the first step, we consider your work activity, if any. If you are doing substantial gainful activity, we will find that you are not disabled. . . . ii. At the second step, we consider the medical severity of your impairment(s). If you do not have a severe medically determinable physical or mental impairment that meets the duration requirement in § 416.909, or a combination of impairments that is severe and meets the duration requirement, we will find that you are not disabled. . . . iii. At the third step, we also consider the medial severity of your impairment(s). If you have an impairment(s) that meets or equals one of our listings in appendix 1 subpart P of part 404 of this chapter and meets the duration requirement, we will find that you are disabled. . . . iv. At the fourth step, we consider our assessment of your residual functional capacity and your past relevant work. If you can still do your past relevant work, we will find that you are not disabled. . . . v. At the fifth and last step, we consider our assessment of your residual functional capacity and your age, education, and work experience to see if you can make an adjustment to other work. If you can make an adjustment to other work, we will find that you are not disabled. If you cannot make an adjustment to other work, we will find that you are disabled. . . . 20 C.F.R. § 404.1520(a)(4). decisions and with few, if any workplace changes. He could have occasional interaction with the general public, co-workers and supervisors. (Id.). The ALJ found that Plaintiff could perform jobs that “exist in significant numbers in the national economy” and therefore, he reached the conclusion that Plaintiff was not disabled, as defined in the Social Security Act. (Id.). Plaintiff’s Statement of Errors seeks reversal on the grounds that the ALJ’s formulation of Plaintiff’s residual functional capacity (“RFC”)3 was not supported by substantial evidence. (ECF No. 10). Plaintiff asserts that the ALJ erred by failing to satisfy his duty to complete the claimant’s medical record and instead based the RFC on raw medical data and claimant testimony. Id. Specifically, Plaintiff claims that the ALJ had an obligation to order a consultative examination or

have a medical expert testify prior to completing the RFC because the ALJ rejected the state agency psychological evaluations in the record and those opinions were formed before Plaintiff’s physical limitations arose. Id. The Commissioner argues in opposition that the ALJ “properly summarized the medical record, and determined that he did not require consultative examiners or a medical expert because he had enough evidence to formulate the RFC.” (ECF No. 11). The Commissioner points out that the ALJ was charged with the responsibility of determining Plaintiff’s RFC and it was completely within the ALJ’s discretion to decide if additional testing or examination was required. Id. On January 9, 2024, the Magistrate Judge issued a Report and Recommendation

recommending that this Court overrule Plaintiff’s Statement of Errors and affirm the decision of the Commissioner of Social Security. (ECF No. 13). The Magistrate Judge explained that ALJs

3 It is recognized that an employee’s physical and mental limitations can affect their abilities in a work setting. The RFC is defined as “the most you can still do despite your limitations.” 20 C.F.R. § 416.945(a)(1). are permitted to interpret medical evidence, like doctors’ reports, without relying on a medical opinion with respect to disability status. (Id. at 9-20). In the Magistrate Judge’s view, the ALJ did so appropriately here regarding both Plaintiff’s mental and physical impairments. (Id.). Plaintiff objected to the Magistrate Judge’s findings, and the Commissioner responded. (ECF Nos. 14, 15). Plaintiff’s Objection is now ripe for review.

II. STANDARD OF REVIEW In a matter regarding an objection to a Magistrate Judge’s Report and Recommendation, this Court must “make a de novo determination of those portions of the report or specified proposed findings or recommendations to which objection is made.” 28 U.S.C. § 636(b)(1); see Fed. R. Civ. P.

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