Lansky v. Commissioner of Social Security

CourtDistrict Court, N.D. Ohio
DecidedMarch 25, 2025
Docket1:24-cv-01231
StatusUnknown

This text of Lansky v. Commissioner of Social Security (Lansky v. Commissioner of Social Security) 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.

Bluebook
Lansky v. Commissioner of Social Security, (N.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

KEITH LANSKY, ) CASE NO. 1:24-CV-01231-JDG ) Plaintiff, ) ) vs. ) MAGISTRATE JUDGE ) JONATHAN D. GREENBERG COMMISSIONER OF SOCIAL ) SECURITY, ) MEMORANDUM OF OPINION AND ) ORDER Defendant. )

Plaintiff, Keith Lansky (“Plaintiff” or “Lansky”), challenges the final decision of Defendant, Leland Dudek,1 Acting Commissioner of Social Security (“Commissioner”), denying his application for Supplemental Security Income (“SSI”) under Title XVI of the Social Security Act, 42 U.S.C. §§ 416(i), 423, and 1381 et seq. (“Act”). This Court has jurisdiction pursuant to 42 U.S.C. § 405(g) and the consent of the parties, pursuant to 28 U.S.C. § 636(c)(2). For the reasons set forth below, the Commissioner’s final decision is AFFIRMED. I. PROCEDURAL HISTORY In June 2021, Lansky filed an application for SSI, alleging a disability onset date of April 1, 1991, and claiming he was disabled due to attention deficit/hyperactivity disorder, bipolar disorder, and spinal cord injury. (Transcript (“Tr.”) at 15, 67.) The application was denied initially and upon reconsideration, and Lansky requested a hearing before an administrative law judge (“ALJ”). (Id. at 15.) On June 29, 2023, an ALJ held a hearing, during which Lansky, represented by counsel, and an impartial vocational expert (“VE”) testified. (Id.) On August 7, 2023, the ALJ issued a written decision

1 On February 19, 2025, Leland Dudek became the Acting Commissioner of Social Security. finding Plaintiff was not disabled. (Id. at 15-34.) The ALJ’s decision became final on June 3, 2024, when the Appeals Council declined further review. (Id. at 1-6.) On July 19, 2024, Lansky filed his Complaint to challenge the Commissioner’s final decision. (Doc. No. 1.) The parties have completed briefing in this case. (Doc. Nos. 8, 10.) Lansky asserts the

following assignments of error: (1) The ALJ found, at step three, that Mr. Lansky’s cognitive impairment did not meet or equal the requirements of Listing 12.05B. This finding is unsupported by substantial evidence when the record documents that Mr. Lansky has a full scale IQ of 55 and Mr. Lansky has significant deficits of adaptive functioning. (2) The ALJ found, at step five, that Mr. Lansky is capable of performing a significant number of jobs in the national economy. This finding is not supported by substantial evidence when the ALJ’s residual functional capacity finding is not an accurate assessment of Mr. Lansky’s mental limitations. (Doc. No. 8.) II. EVIDENCE A. Personal and Vocational Evidence Lansky was born in August 1984 and was 38 years-old at the time of his administrative hearing (Tr. 15, 32), making him a “younger” person under Social Security regulations. See 20 C.F.R. § 416.963(c). He has at least a high school education. (Tr. 33.) He has no past relevant work. (Id. at 32.) B. Relevant Medical Evidence2 On August 24, 2018, Lansky saw Megan Raleigh, LISW, for a mental health biopsychosocial assessment at Lorain Correctional Institution. (Id. at 427.) Raleigh noted the reason for referral as possible intellectual and developmental disability. (Id.) Raleigh further noted a review of Lansky’s past incarceration records revealed he met the criteria for mild intellectual disability and had been on the

2 The Court’s recitation of the medical evidence is not intended to be exhaustive and is limited to the evidence cited in the parties’ Briefs. As Lansky challenges only the ALJ’s findings regarding his mental limitations, the Court further limits its discussion of the evidence to Evans’ mental impairments. mental health caseload before for mild intellectual disability, but there was no history of mood dysfunction or mental health concerns. (Id.) Lansky described his concentration as “‘average,’” although he could not focus on a book if he wanted to, and described his mood as “‘content.’” (Id.) He denied feeling helpless or hopeless. (Id.) He endorsed an average energy level and good sleep. (Id.) He described reading as one of his coping skills. (Id. at 429.) Raleigh noted Lansky was engaged in the assessment and answered

questions appropriately. (Id. at 427.) On examination, Raleigh found organized and linear thought content. (Id.) Raleigh further found normal speech, although there was “[s]ome impairment with pronunciation” that may be related to Lansky’s intellectual disability, euthymic mood and affect, and full orientation. (Id. at 432.) Raleigh noted Lansky appeared to have “subaverage intelligence per Mild IDD dx and CASAS scores.” (Id.) His attention seemed average, and his concentration seemed fair, although he needed “some redirection” even though he was responsive. (Id.) Raleigh further found intact memory and poor judgment and insight. (Id.) Raleigh referred Lansky to counseling once a month “to build socialization skills and personal communication goals,” and five sessions of coping skills psychoeducational group therapy “to build on group socialization and interpersonal communication.” (Id.

at 433.) On November 6, 2019, Lansky saw psychologist Kimberly Kohli for counseling while at Marion Correctional Institution. (Id. at 340.) Lansky denied any issues or concerns and reported good sleep and appetite. (Id.) On examination, Dr. Kohli found full orientation, concrete thoughts, direct eye contact, pleasant and talkative demeanor, cooperative behavior, calm mood and congruent affect, and intact memory. (Id.) On July 30, 2020, Lansky saw R. Davison, LSW MHL, for a 30-day release planning meeting. (Id. at 280-81.) Lansky told Davison he was doing well and looking forward to his release in August 2020. (Id. at 280.) Lansky reported he would be going to Oriana House upon release, where he would receive case management services. (Id. at 280.) On examination, Davison found normal appearance, euthymic mood, and no observable mental health signs or symptoms. (Id. at 281.) Davison noted Lansky was “deemed stable in mood and functioning.” (Id.) On August 18, 2020, Lansky underwent a Non-Medical-Psychiatric Diagnostic Assessment. (Id. at 473.) Lansky endorsed depressed mood and mood swings. (Id. at 484-85.) Although he denied

anxiety, treatment providers noted Lansky appeared anxious throughout the assessment, as he “was very fidgety and shook his legs the entire time.” (Id. at 484.) On examination, treatment providers found full orientation, intact memory, attention, and concentration, below average intellect, impaired abstract thinking, intact impulse control, intact judgment, impaired insight, anxious/worrisome appearance, cooperative attitude, depressed mood and affect, intact thought process, normal speech, and good eye contact. (Id. at 487-88.) Treatment providers noted Lansky “has a history of prior treatment of both SUD and MH and a pattern is evident in that when in a controlled environment he begins to stabilize the MH and SUD symptoms.” (Id. at 489.) Treatment providers further noted Lansky would benefit from part-time employment and help with getting his SSI benefits. (Id.)

On May 4, 2021, Lansky saw Amber Bundy, LPCC, for a behavioral health assessment. (Id. at 851-61.) Lansky reported being homeless with no income and no food stamps, and that he needed to be connected to psychiatric services so he could resume his medications. (Id.

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

Related

Sullivan v. Zebley
493 U.S. 521 (Supreme Court, 1990)
Thomas Bryan v. Commissioner Social Security
383 F. App'x 140 (Third Circuit, 2010)
Kirk v. Secretary of Health and Human Services
667 F.2d 524 (Sixth Circuit, 1981)
Yer Her v. Commissioner of Social Security
203 F.3d 388 (Sixth Circuit, 1999)
Ruby E. Heston v. Commissioner of Social Security
245 F.3d 528 (Sixth Circuit, 2001)
David Bowen v. Commissioner of Social Security
478 F.3d 742 (Sixth Circuit, 2007)
Debra Rogers v. Commissioner of Social Security
486 F.3d 234 (Sixth Circuit, 2007)
Ealy v. Commissioner of Social Security
594 F.3d 504 (Sixth Circuit, 2010)
White v. Commissioner of Social Security
572 F.3d 272 (Sixth Circuit, 2009)
Fleischer v. Astrue
774 F. Supp. 2d 875 (N.D. Ohio, 2011)
Gentry v. Commissioner of Social Security
741 F.3d 708 (Sixth Circuit, 2014)
Burbridge v. Commissioner of Social Security
572 F. App'x 412 (Sixth Circuit, 2014)

Cite This Page — Counsel Stack

Bluebook (online)
Lansky v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lansky-v-commissioner-of-social-security-ohnd-2025.