Lanham v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedNovember 20, 2024
Docket2:24-cv-01156
StatusUnknown

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

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

CHRISTINA L.1

Plaintiff,

v. Civil Action 2:24-cv-1156 Magistrate Judge Chelsey M. Vascura

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

OPINION AND ORDER Plaintiff, Christina L. (“Plaintiff”), brings this action under 42 U.S.C. § 405(g) for review of a final decision of the Commissioner of Social Security (“Commissioner”) denying her applications for Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”). This matter is before the Court for a ruling on Plaintiff’s Statement of Errors (ECF No. 8), the Commissioner’s Memorandum in Opposition (ECF No. 10), and the administrative record (ECF No. 7). Plaintiff has not filed a Reply. For the reasons that follow, the Commissioner’s non-disability determination is AFFIRMED, and Plaintiff’s Statement of Errors is OVERRULED. I. BACKGROUND Plaintiff protectively filed her DIB and SSI applications on May 18, 2020, alleging that she became disabled that same day. After Plaintiff’s applications were denied at the initial and reconsideration levels, an administrative law judge (“ALJ”) held an online video hearing on

1 Pursuant to this Court’s General Order 22-01, any opinion, order, judgment, or other disposition in Social Security cases shall refer to plaintiffs by their first names and last initials. December 14, 2022. Plaintiff, who was represented by counsel, and a vocational expert (“VE”) participated in that hearing. On January 27, 2023, the ALJ issued an unfavorable determination, which became final on January 17, 2024, when the Appeals Council denied Plaintiff’s request for review. Plaintiff seeks judicial review of that final determination. She asserts that the ALJ

committed three reversible errors. First, she contends that the ALJ erred by failing to find that her fibromyalgia was a medically determinable impairment. (Pl.’s Statement of Errors 17–19, ECF No. 8.) Next, she contends that the ALJ erred when adopting findings from state agency reviewers that she could perform light work even though evidence that was unavailable to the reviewers showed that she could not. (Id. at 19–23.) Last, Plaintiff contends that the ALJ erred by finding a consultative examiner’s opinion persuasive but failing to incorporate into her residual functional capacity (“RFC”)2 the limits that the examiner opined. (Id. at 23–25.) The Commissioner contends that Plaintiff’s contentions lack merit. (Df.’s Memorandum in Opp., 4– 12, ECF No. 10.) The Court agrees.

II. THE ALJ’S DECISION On January 27, 2024, the ALJ issued a decision finding that Plaintiff was not disabled within the meaning of the Social Security Act. (R. 18–36.) At step one of the sequential

2 A claimant’s RFC is an assessment of “the most [she] can still do despite [her] limitations.” 20 C.F.R. § 404.1545(a)(1).

evaluation process,3 the ALJ found that Plaintiff had not engaged in substantially gainful activity since the alleged onset date of May 18, 2020. (Id. at 21.) At step two, the ALJ found that Plaintiff had the following severe impairments: obesity, degenerative disc disease with left-sided cervical radiculopathy, plantar fasciitis, left carpal tunnel syndrome, bilateral hip osteoarthritis, hypertension, right elbow calcification/ossification, and depressive disorder. (Id.) The ALJ also

found that Plaintiff had the following non-severe impairments: presbyopia, adnexal cyst, hypothyroidism, vitamin D deficiency, multinodular non-toxic goiter, Seborrheic keratosis, multiple skin nodules, left inguinal abscess, viral upper respiratory infection, acute bronchitis, and allergic rhinitis. (Id.) The ALJ also determined that Plaintiff’s alleged fibromyalgia and migraine headaches were non-medically determinable impairments. (Id. at 22.) At step three, the ALJ found that Plaintiff did not have an impairment or combination of impairments that met or medically equaled one of the listed impairments described in 20 C.F.R.

3 Social Security Regulations require ALJs to resolve a disability claim through a five-step sequential evaluation of the evidence. See 20 C.F.R. § 404.1520(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. § 404.1520(a)(4); see also Henley v. Astrue, 573 F.3d 263, 264 (6th Cir. 2009); Foster v. Halter, 279 F.3d 348, 354 (6th Cir. 2001). Part 404, Subpart P, Appendix 1. (Id. at 22–25.) Before proceeding to step four, the ALJ set forth Plaintiff’s RFC as follows: [Plaintiff] has the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) and 416.967(b) except that she can frequently operate hand controls with the left hand and frequently operate foot controls, bilaterally; she can frequently reach, bilaterally; she can frequently handle and finger items with the left hand. She can never crawl or climb ladders, ropes, or scaffolds; she can occasionally crouch and climb ramps and stairs; she can frequently balance, stoop, and kneel. She can tolerate occasional exposure to vibration and work at unprotected heights or around moving mechanical parts; she can tolerate frequent exposure to extreme cold and operation of a motor vehicle. She must wear prescription eye glasses or contact lenses at all times. Additionally, she can perform simple work in a routine work environment involving no greater than occasional changes and no fast-paced production requirements. (Id. at 25–26.) At step four, the ALJ determined that Plaintiff would be unable to perform her past relevant work as a mail carrier, secretary, human resources manager or accounting clerk. (Id. at 34.) At step five, the ALJ, relying upon testimony from the VE, found that jobs existed in significant numbers in the national economy that an individual with Plaintiff’s age, education, work experience, and residual functional capacity could perform, with representative occupations being sorter, bagger, and tabber. (Id. at 34–35.) The ALJ therefore concluded that Plaintiff was not disabled under the Social Security Act during the relevant period. (Id. at 35–36.) III. STANDARD OF REVIEW When reviewing a case under the Social Security Act, the Court “must affirm a decision by the Commissioner as long as it is supported by substantial evidence and was made pursuant to proper legal standards.” DeLong v. Comm’r of Soc.

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