Jordan v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedSeptember 26, 2022
Docket3:21-cv-00156
StatusUnknown

This text of Jordan v. Commissioner of Social Security (Jordan 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
Jordan v. Commissioner of Social Security, (S.D. Ohio 2022).

Opinion

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

RHYAN J.,1 : Case No. 3:21-cv-00156 : Plaintiff, : Magistrate Judge Caroline H. Gentry : (by full consent of the parties) vs. : : COMMISSIONER OF THE SOCIAL : SECURITY ADMINISTRATION, : : Defendant. :

DECISION AND ORDER

I. INTRODUCTION

Plaintiff filed applications for Disability Insurance Benefits and Supplemental Security Income in November 2016. Plaintiff’s claims were denied initially and upon reconsideration. After a hearing at Plaintiff’s request, the Administrative Law Judge (ALJ) concluded that Plaintiff was not eligible for benefits because she was not under a “disability” as defined in the Social Security Act. The Appeals Council granted Plaintiff’s request for review, vacated the ALJ’s decision, and remanded the case to the ALJ for resolution of several issues. Upon remand, the ALJ held a second hearing and issued a

1 See S.D. Ohio General Order 22-01 (“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 claimants only by their first names and last initials.”). 1 written decision, again concluding that Plaintiff was not disabled. The Appeals Council denied Plaintiff’s request for review. Plaintiff subsequently filed this action.

Plaintiff seeks an order remanding this matter to the Commissioner for the award of benefits or, in the alternative, for further proceedings. The Commissioner asks the Court to affirm the non-disability decision. This matter is before the Court upon Plaintiff’s Statement of Errors (Doc. 11), the Commissioner’s Memorandum in Opposition (Doc. 15), Plaintiff’s Reply (Doc. 16), and the administrative record (Doc. 8).

II. BACKGROUND Plaintiff asserts that she has been under a disability since August 26, 2014. At that time, she was twenty-three years old. At the time of the second administrative decision, she was thirty years old. Accordingly, Plaintiff was considered a “younger person” under Social Security Regulations. See 20 C.F.R. § 404.1563(d); 20 C.F.R. § 416.963(c).2 Plaintiff has a “high school education and above.” 20 C.F.R. § 404.1564(b)(4).

The evidence in the administrative record is summarized in the ALJ’s decision (Doc. 8-2, PageID 44-60), Plaintiff’s Statement of Errors (Doc. 11), the Commissioner’s Memorandum in Opposition (Doc. 15), and Plaintiff’s Reply (Doc. 16.) Rather than repeat these summaries, the Court will discuss the pertinent evidence in its analysis below.

2 The remaining citations will identify only the pertinent Disability Insurance Benefits Regulations, as they are similar in all relevant respects to the corresponding Supplemental Security Income Regulations. 2 III. STANDARD OF REVIEW The Social Security Administration provides Disability Insurance Benefits and

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. §§ 423(a)(1), 1382(a); 42 U.S.C. §§ 402(e), 402(e)(B)(ii). The term “disability” means “the inability to do any substantial gainful activity by reason of any medically determinable physical or mental impairment which … has lasted or can be expected to last for a continuous period of not less than 12 months.” 20 C.F.R. § 404.1505(a).

This Court’s review of an ALJ’s unfavorable decision is limited to two inquiries: “whether the ALJ applied the correct legal standards and whether the findings of the ALJ are supported by substantial evidence.” Blakley v. Comm’r of Soc. Sec., 581 F.3d 399, 406 (6th Cir. 2009); see 42 U.S.C. § 405(g) (“The findings of the Commissioner of Social Security as to any fact, if supported by substantial evidence, shall be conclusive.”).

“Unless the ALJ has failed to apply the correct legal standards or has made findings of fact unsupported by substantial evidence,” this Court must affirm the ALJ’s decision. Emard v. Comm’r of Soc. Sec., 953 F.3d 844, 849 (6th Cir. 2020). Thus, the Court “may not try the case de novo, nor resolve conflicts in evidence, nor decide questions of credibility.” (Id.)

“Under the substantial-evidence standard, a court looks to an existing administrative record and asks whether it contains ‘sufficien[t] evidence’ to support the agency’s factual determinations.” Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) 3 (citation omitted). This limited standard of review does not permit the Court to weigh the evidence and decide whether the preponderance of the evidence supports a different

conclusion. Instead, the Court is confined to determining whether the ALJ’s decision is supported by substantial evidence, which “means - and means only – ‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” (Id.) (citation omitted). The other line of judicial inquiry—reviewing the correctness of the ALJ’s legal criteria—may result in reversal even when the record contains substantial evidence

supporting the ALJ’s factual findings. Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647, 651 (6th Cir. 2009). “[E]ven if supported by substantial evidence, ‘a decision of the Commissioner will not be upheld where the SSA fails to follow its own regulations and where that error prejudices a claimant on the merits or deprives the claimant of a substantial right.’” Rabbers, 582 F.3d at 651 (citations omitted). Such an error of law will

require reversal even if “the outcome on remand is unlikely to be different.” Cardew v. Comm’r of Soc. Sec., 896 F.3d 742, 746 (6th Cir. 2018) (internal quotations and citations omitted). IV. FACTS A. The ALJ’s Findings of Fact

The ALJ was tasked with evaluating the evidence related to Plaintiff’s applications for benefits. In doing so, the ALJ considered each of the five sequential steps set forth in the regulations. See 20 C.F.R. § 404.1520. The ALJ made the following findings of fact: 4 Step 1: Plaintiff has engaged in substantial gainful activity since August 26, 2014, the alleged onset date.

However, there has been a continuous 12-month period(s) during which Plaintiff did not engage in substantial gainful activity. The remaining findings address the period(s) Plaintiff did not engage in substantial gainful activity.

Step 2: She has the severe impairments of autism spectrum disorder, anxiety/dependent personality disorder, and sensory disorder.

She has the following nonsevere impairment: fine motor skill coordination.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Bowen v. City of New York
476 U.S. 467 (Supreme Court, 1986)
Bl(a)ck Tea Society v. City of Boston
378 F.3d 8 (First Circuit, 2004)
Jimmie L. Howard v. Commissioner of Social Security
276 F.3d 235 (Sixth Circuit, 2002)
Debbie Webb v. Commissioner of Social Security
368 F.3d 629 (Sixth Circuit, 2004)
Robert M. Wilson v. Commissioner of Social Security
378 F.3d 541 (Sixth Circuit, 2004)
Debra Rogers v. Commissioner of Social Security
486 F.3d 234 (Sixth Circuit, 2007)
Charles Gayheart v. Commissioner of Social Security
710 F.3d 365 (Sixth Circuit, 2013)
Blakley v. Commissioner of Social Security
581 F.3d 399 (Sixth Circuit, 2009)
Gentry v. Commissioner of Social Security
741 F.3d 708 (Sixth Circuit, 2014)
Price v. Commissioner Social Security Administration
342 F. App'x 172 (Sixth Circuit, 2009)
Ronald Miller v. Comm'r of Social Security
811 F.3d 825 (Sixth Circuit, 2016)
Rebecca Hernandez v. Comm'r of Social Security
644 F. App'x 468 (Sixth Circuit, 2016)
Bradley Cardew v. Comm'r of Soc. Sec.
896 F.3d 742 (Sixth Circuit, 2018)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Jeffery Emard v. Comm'r of Soc. Sec.
953 F.3d 844 (Sixth Circuit, 2020)
David Hargett v. Comm'r of Soc. Sec.
964 F.3d 546 (Sixth Circuit, 2020)

Cite This Page — Counsel Stack

Bluebook (online)
Jordan v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jordan-v-commissioner-of-social-security-ohsd-2022.