Jon Sims, Sr. v. Commissioner, Social Security Administration

CourtDistrict Court, W.D. Pennsylvania
DecidedDecember 19, 2025
Docket1:24-cv-00312
StatusUnknown

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

Bluebook
Jon Sims, Sr. v. Commissioner, Social Security Administration, (W.D. Pa. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF PENNSYLVANIA ERIE JON SIMS, SR., ) ) Plaintiff, ) 1:24-CV-00312-MJH vs. ) ) COMMISSIONER, SOCIAL SECURITY ) ) ADMINISTRATION, ) ) Defendant,

OPINION Pending before the court is an appeal from the final decision of the Commissioner of Social Security denying the claim of Jon Sims, Sr. for Social Security Disability Insurance (“SSDI”) and Supplemental Social Security Income (“SSI”) under of the Social Security Act (“SSA”), 42 U.S.C. §§ 405(g). Mr. Sims contends the Administrative Law Judge (the “ALJ”) erred by failing to properly weigh the medical opinion evidence of Mr. Sims treating psychiatric physicians and Mr. Sims’s testimony. The parties filed cross-motions for summary judgment pursuant to Rule 56(c) of the Federal Rules of Civil Procedure. The matter is now ripe for decision. Following consideration of the underlying administrative record (ECF No. 7), the respective motions and briefs (ECF Nos. 9, 10, 11, and 12), and for the following reasons, Plaintiff’s Motion for Summary Judgment will be denied, and Defendant’s Motion for Summary Judgment will be granted. I. Relevant Law and Background A. Social Security Disability Eligibility To be eligible for Social Security benefits under the SSA, a claimant must demonstrate that he or she cannot engage in “substantial gainful activity” because of a medically determinable physical or mental impairment which can be expected to result in death, or which has lasted or can be expected to last for a continuous period of at least twelve months. 42 U.S.C. § 423(d)(1)(A); Brewster v. Heckler, 786 F.2d 581, 583 (3d Cir. 1986). When reviewing a claim, the ALJ must utilize a five-step sequential analysis to evaluate whether a claimant has met the requirements for disability. 20 C.F.R. §§ 404.1520, 416.920. The ALJ must determine:

1. whether the claimant is currently engaged in substantial gainful activity;

2. if not, whether the claimant has a severe impairment or a combination of impairments that is severe;

3. whether the medical evidence of the claimant's impairment or combination of impairments meets or equals the criteria listed in 20 C.F.R., Pt. 404, Subpt. P, App’x 1;

4. whether the claimant’s impairments prevent him from performing his past relevant work; and

5. if the claimant is incapable of performing his past relevant work, whether he can perform any other work which exists in the national economy. 20 C.F.R. §§ 404.1520(a)(4), 416.920(a)(4); see Barnhart v. Thomas, 540 U.S. 20, 24–25 (2003).

If the claimant is determined to be unable to resume previous employment, the burden shifts to the SSA/Commissioner at Step 5 to prove that, given claimant’s mental or physical limitations, age, education, and work experience, he or she is able to perform substantial gainful activity in jobs available in the national economy. Doak v. Heckler, 790 F.2d 26, 28 (3d Cir. 1986). B. Background In his application for Social Security Disability, Mr. Sims asserted his ability to work was limited by 1) degenerative back issues; 2) anxiety; 3) depression; and 4) bipolar disorder. (ECF No. 7-7 at p. 3). In this appeal, Mr. Sims only raises mental health impairments. Mr. Sims alleges disability since March 2021. In January 2022, M. Sims first sought treatment through a psychiatric evaluation wherein he reported mood swings, paranoia, and anxiety. (ECF No. 7-8 at p. 3). The administrative recorded includes Psychiatric treatment records through September 2023. Upon examination, providers described Mr. Sims as having an anxious mood, an irritable and anxious affect, and normal speech and memory. The psychiatrist prescribed Geodon; and thereafter, Mr. Sims attended medication check appointments every one to two months.

At his March 2022 follow-up, Mr. Sims reported improvement since starting Geodon. Objectively, Mr. Sim’s mental status exam was improved with the only indications of a dysthymic (depressive) mood. (ECF No. 7-8). Because of complaints of pain, Mr. Sims was prescribed Cymbalta, in addition to Geodon, for treatment of both pain and depression. In May 2022, Mr. Sims’s doses were increased; and a few months later, he reported more stability on the medications. Id. Mr. Sims’s mental status exams remained stable during this period with only occasional findings of a dysthymic mood, and no abnormalities in thoughts processes, memory, or speech. In early 2023, Mr. Sims’s mental health providers increased his Geodon dose after he reported some anger and mood swings. (ECF No. 7-9). A few weeks later, Mr. Sims reported

that his medication adjustment had a positive result. In April 2023, Mr. Sims’s Cymbalta dose was also increased. For about a month in August 2023, Mr. Sims discontinued his medications; but then asked for his medications to be restarted, because he noticed he was significantly worse without the medicine. (ECF No. 7-10). After restarting the medications, Mr. Sims reported less anger and depression, and his September 2023 mental status exam was “completely normal.” C. Mr. Sims’s Testimony At the ALJ hearing, Mr. Sims testified that he ceased working on March 20, 2020 due to an inability to get along with his coworkers and his supervisors. He further testified that this had been an ongoing, persistent struggle for him. (ECF No. 7-2). Mr. Sims clarified that he would have become violent with his coworkers had he continued to work. Id. Additionally, Mr. Sims testified that, while at this job, he would frequently “just walk away for a little bit” in order to calm down and gather himself before being able to return resume his work duties. Id. Mr. Sims asserted that, even when he appropriately decided to step away as opposed to becoming violent,

it was a constant struggle interacting with others. Id. Ultimately, Mr. Sims felt that the struggle to control his mental health symptoms became too overpowering, which led him to leaving a job he once thoroughly enjoyed. Id. Mr. Sims testified extensively on how his mental health symptoms have not improved despite no longer working. D. ALJ’s Decision Following a hearing on Mr. Sim’s application for a period of disability and disability insurance benefits, the ALJ made the following findings under the five-step sequential analysis: *** 2. The claimant has not engaged in substantial gainful activity since March 20, 2021, the alleged onset date (20 CFR 404.1571 et seq., and 416.971 et seq.). [STEP 1]

3. The claimant has the following severe impairments: lumbar degenerative disc disease, anxiety, depression, schizophrenia spectrum disorder, gastroesophageal reflux disorder, hypertension, obesity, and alcohol use disorder (20 CFR 404.1520(c) and 416.920(c)). [STEP 2]

4.

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