Kurman v. Commissioner of Social Security Administration

CourtDistrict Court, N.D. Ohio
DecidedMarch 14, 2022
Docket1:20-cv-01837
StatusUnknown

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

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Kurman v. Commissioner of Social Security Administration, (N.D. Ohio 2022).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO

: DANIELLE KURMAN, : CASE NO. 1:20-cv-01837 : Plaintiff, : OPINION & ORDER : [Resolving Docs. 1; 12] v. : : COMMISSIONER OF SOCIAL : SECURITY, : : Defendant. :

JAMES S. GWIN, UNITED STATES DISTRICT COURT JUDGE:

Plaintiff Danielle Kurman seeks judicial review of the Social Security Commissioner’s final decision denying Plaintiff’s application for disability insurance benefits.1 In support of her request for review, Plaintiff Kurman argues that substantial evidence did not support the Administrative Law Judge’s finding that Plaintiff can perform light work because the Administrative Law Judge (“ALJ”) did not properly analyze Plaintiff’s subjective complaints.2 Defendant Social Security Commissioner opposes.3 Magistrate Judge David A. Ruiz filed a Report and Recommendation, recommending the Court affirm the Commissioner’s decision.4 Plaintiff Kurman objects.5 The Commissioner responds.6 With this decision, the Court determines whether the Social Security

1 Doc. 1. 2 Doc. 12. 3 Doc. 14. 4 Doc. 15. Local Rule 72.2(b). 5 Doc. 17. Commissioner’s evaluation of Plaintiff’s subjective symptoms and subsequent residual functional capacity finding was “supported by substantial evidence and made pursuant to proper legal standards.”7

For the following reasons, the Court OVERRULES Plaintiff’s objections and ADOPTS Magistrate Judge Ruiz’s Report and Recommendation. I. Background In April 2018, Plaintiff Kurman applied for disability insurance benefits.8 She claims that her chronic pain and mental health conditions disable her from employment.9 The Social Security Administration denied Kurman’s application initially and upon

reconsideration.10 Kurman requested a hearing before a Social Security ALJ.11 On October 9, 2019, an ALJ conducted a hearing on Kurman’s case and found her not disabled.12 The ALJ determined that Kurman had the residual functional capacity to perform light work with some limitations and could therefore perform a number of jobs in the national economy.13 The Appeals Council declined to further review Kurman’s case.14 The ALJ’s decision is the Social Security Commissioner’s final decision.

On August 18, 2020, Plaintiff Kurman filed this case seeking judicial review of the Commissioner’s final decision.15 In her merits brief, Plaintiff asserts that the ALJ’s finding that Plaintiff can perform light work was not supported by substantial evidence because the ALJ

7 , 486 F.3d 234, 241 (6th Cir. 2007); 42 U.S.C. § 405(g). 8 Doc. 10 at 200-01. For consistency, this opinion cites to the PDF page number of the relevant document. 9 10 at 126-36. 11 at 137. 12 at 28, 52-90. 13 Doc. 10 at 37-46. 14 at 5-11. failed to properly analyze Plaintiff’s subjective symptoms.16 Defendant filed a responding merits brief arguing that the ALJ properly evaluated Plaintiff’s subjective complaints pursuant to the regulations and substantial evidence supported the ALJ’s assessment.17

On January 13, 2022, Magistrate Judge Ruiz issued a Report and Recommendation, recommending the Court affirm the Commissioner’s final decision denying Plaintiff’s application.18 Magistrate Judge Ruiz found that the ALJ’s assessment of Plaintiff’s subjective symptoms followed regulations and was supported by substantial evidence.19 II. Legal Standard The Court reviews the objected-to portions of a Magistrate Judge’s Report

and Recommendation.20 When reviewing an ALJ’s disability determination under the Social Security Act, a district court decides whether the ALJ’s decision is “supported by substantial evidence and [is] made pursuant to proper legal standards.”21 Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.”22 It is more than a scintilla of evidence, but less than a preponderance.23 A district court should not try to resolve “conflicts in evidence[] or decide questions

of credibility.”24 A district court may not reverse an ALJ’s decision when substantial evidence

16 Doc. 12 at 12-18. 17 Doc. 14 at 5-15. 18 Doc. 15. 19 at 10-21. 20 28 U.S.C. § 636(b)(1). 21 , 486 F.3d at 241; 42 U.S.C. § 405(g); , 478 F.3d 742, 746 (6th Cir. 2006) (“[A] decision . . . will not be upheld [when] the SSA fails to follow its own regulations and [when] that error prejudices a claimant on the merits or deprives the claimant of a substantial right.”). 22 , 402 U.S. 389, 401 (1971) (internal quotation marks omitted). 23 supports it, even if the court would have made a different decision.25 III. Discussion Kurman argues that substantial evidence does not support the ALJ’s determination that

Plaintiff can perform and sustain light work because he did not properly analyze Plaintiff’s subjective symptoms.26 Specifically, Plaintiff says the ALJ did not properly evaluate her symptoms pursuant to Social Security Rulings 16-3p and 03-2p. When a claimant alleges symptoms of disabling severity, the ALJ follows a two-step process for evaluating these symptoms.27 First, the ALJ must determine if there is an underlying medically determinable physical or mental impairment that could reasonably be

expected to produce the claimant’s symptoms.28 If such an impairment exists, then the ALJ must next “evaluate the intensity and persistence of [the claimant’s] symptoms so that [the ALJ] can determine how [those] symptoms limit [the claimant’s] capacity for work.”29 In evaluating a claimant’s alleged symptoms, the ALJ considers factors including: 1) daily activities; 2) location, duration, frequency, and intensity of pain or symptoms; 3) precipitating and aggravating factors; 4) the type, dosage, effectiveness, and side effects of any medication; 5) treatment, other than medication, to relieve pain; 6) any measures used

to relieve pain; and 7) other factors concerning functional limitations and restrictions due to pain or other symptoms.30 However, an “ALJ need not analyze all seven factors.”31

25 , 823 F.2d 918, 920 (6th Cir. 1987); , 336 F.3d 469, 477 (6th Cir. 2003) (holding that an ALJ’s decision cannot be overturned so long as the ALJ’s decision was supported by substantial evidence). 26 Doc. 12 at 12-18. 27 , , 409 F. App’x 917, 921 (6th Cir. 2011). 28 , 486 F.3d at 247 (citing 20 C.F.R. § 416.929(a)). 29 20 C.F.R. § 416.929(c)(1). 30 20 C.F.R. § 416.929(c)(3). 31 , Case No. 1:18-cv-1123, 2019 WL 1382288, at *15 (N.D. Ohio March 27, 2019) (internal An ALJ’s evaluation of subjective symptoms is accorded great weight and deference.32 The ALJ, and not the reviewing court, must make credibility determinations regarding the claimant’s subjective complaints.33 The ALJ’s decision, however, must be rooted in the

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Kurman v. Commissioner of Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kurman-v-commissioner-of-social-security-administration-ohnd-2022.