Howell v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedJune 12, 2025
Docket3:24-cv-00130
StatusUnknown

This text of Howell v. Commissioner of Social Security (Howell 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
Howell v. Commissioner of Social Security, (S.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF OHIO WESTERN DIVISION AT DAYTON

JASON H.,1

Plaintiff, Civil Action 3:24-cv-130 v. Judge Michael J. Newman Magistrate Judge Elizabeth P. Deavers

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

REPORT AND RECOMMENDATION

Plaintiff, Jason H., brings this action under 42 U.S.C. § 405(g) for review of a decision of the Commissioner of Social Security (“Commissioner”) denying his application for Social Security Supplemental Security Income benefits (“SSI”). This matter is before the United States Magistrate Judge for a Report and Recommendation on Plaintiff’s Statement of Errors (ECF No. 7), the Commissioner’s Memorandum in Opposition, (ECF No. 8), Plaintiff’s Reply (ECF No. 9), and the administrative record (ECF No. 5). For the following reasons, it is RECOMMENDED that the Court OVERRULE Plaintiff’s Statement of Errors (ECF No. 7) and AFFIRM the Commissioner’s decision.

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. 1 I. BACKGROUND Plaintiff applied for SSI on December 1, 2021, alleging disability beginning June 27, 2019, due to lumbar pain, bulging discs at L4-L5, severe depression, COPD, emphysema, IBS, anxiety, sleep apnea, ambulates with prescribed cane/walker. (R. at 207-16, 226.) Plaintiff’s application was denied initially in June 2022, and upon reconsideration in September 2022. (R. at 95-117, 123-34.) On March 21, 2023, Plaintiff, who was represented by counsel, appeared

and testified telephonically at a hearing held by an administrative law judge. (R. at 43-70.) On April 19, 2023, Gregory M. Beatty (the “ALJ”) issued a decision finding that Plaintiff was not disabled within the meaning of the Social Security Act. (R. at 15-42.) The Appeals Council denied Plaintiff’s request for review and adopted the ALJ’s decision as the Commissioner’s final decision. (R. at 1-6.) II. RELEVANT RECORD EVIDENCE The Court has thoroughly reviewed the transcript in this matter, including Plaintiff’s medical records, function and disability reports, and testimony as to his conditions and resulting limitations. Given the claimed errors raised by Plaintiff, rather than summarizing that information here, the Court will refer and cite to it as necessary in the discussion of the parties’

arguments below.

2 III. ADMINISTRATIVE DECISION On April 19, 2023, the ALJ issued the non-disability determination. (R. at 15-42.) At step one of the sequential evaluation process,2 the ALJ found that Plaintiff has not engaged in substantially gainful activity since December 1, 2021, the application date. (R. at 20.) He found that Plaintiff had the following severe impairments: lumbar spondylosis and spondylolisthesis;

gout; carpal tunnel syndrome; alcoholic hepatitis and cirrhosis; essential hypertension; COPD; obstructive sleep apnea; obesity; a depressive disorder; an anxiety disorder; and an alcohol use disorder. (R. at 20-21.) He concluded, however, that Plaintiff’s impairments are not of a severity that medically meets or equals the severity of any impairments listed in Part B of Appendix 1 to Subpart P, 20 C.F.R. Part 404. (R. at 21.)

2 Social Security Regulations require ALJs to resolve a disability claim through a five- step sequential evaluation of the evidence. See 20 C.F.R. § 416.920(a)(4). Although a dispositive finding at any step terminates the ALJ’s review, see Colvin v. Barnhart, 475 F.3d 727, 730 (6th Cir. 2007), if fully considered, the sequential review considers and answers five questions:

1. Is the claimant engaged in substantial gainful activity? 2. Does the claimant suffer from one or more severe impairments? 3. Do the claimant’s severe impairments, alone or in combination, meet or equal the criteria of an impairment set forth in the Commissioner’s Listing of Impairments, 20 C.F.R. Subpart P, Appendix 1? 4. Considering the claimant's residual functional capacity, can the claimant perform his or her past relevant work? 5. Considering the claimant’s age, education, past work experience, and residual functional capacity, can the claimant perform other work available in the national economy?

See 20 C.F.R. § 416.920(a)(4); see also Henley v. Astrue, 573 F.3d 263, 264 (6th Cir. 2009); F oster v. Halter, 279 F.3d 348, 354 (6th Cir. 2001). 3 Before proceeding to step four, the ALJ set forth Plaintiff’s residual functional capacity (“RFC”), in pertinent part, as follows: [Plaintiff] has the residual functional capacity to perform sedentary work as defined in 20 CFR 416.967(a) with no climbing of ladders, ropes, or scaffolds and occasional climbing of ramps and stairs. He is able to frequently balance and crouch with occasional stooping, kneeling, and crawling. He is able to frequently reach overhead, reach in all other directions, and handle items with the bilateral upper extremities. He is able to frequently push and pull with the bilateral upper and lower extremities, and he is able to frequently use foot and hand controls. He is limited to no work at unprotected heights, around moving mechanical parts, or operating a motor vehicle. He is able to tolerate frequent exposure to vibration, humidity, wetness, dusts, odors, fumes, and pulmonary irritants. He is able to perform simple, routine, and repetitive tasks but not at a production-rate pace.

(R. at 24.) At step four, the ALJ determined that Plaintiff is unable to perform his past relevant work as a customer service representative or a sales clerk/store keeper. (R. at 36.) At step five, relying on the VE’s testimony, the ALJ concluded that Plaintiff can perform jobs that exist in significant numbers in the national economy such as an inspector, bench assembler, and packager. (R. at 37-38.) The ALJ therefore concluded that Plaintiff has not been under a disability, as defined in the Social Security Act, since December 1, 2021, the date the application was filed. (R. at 38.) IV. STANDARD OF REVIEW When reviewing a case under the Social Security Act, the Court “must affirm the Commissioner’s decision if it ‘is supported by substantial evidence and was made pursuant to proper legal standards.’” Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647, 651 (6th Cir. 2009) (quoting Rogers v. Comm’r of Soc. Sec., 486 F.3d 234, 241 (6th Cir. 2007)); see also 42 U.S.C. § 4 405(g) (“[t]he findings of the Commissioner of Social Security as to any fact, if supported by substantial evidence, shall be conclusive . . . .”).

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