Lisa P. v. Commissioner of Social Security

District Court, S.D. Ohio·Decided August 20, 2026·No. 3:25-cv-00276·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION LISA P.,1 Plaintiff, v. Civil Action 3:25-cv-276 Magistrate Judge Chelsey M. Vascura COMMISSIONER OF SOCIAL SECURITY, Defendant.

OPINION AND ORDER Plaintiff, Lisa P. (“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 application for a period of disability and disability insurance benefits (“DIB”). This matter is before the Court on Plaintiff’s Statement of Errors (ECF No. 9), the Commissioner’s Memorandum in Opposition (ECF No. 10), and the administrative record (ECF No. 8). For the reasons that follow, the Commissioner’s non-disability determination is AFFIRMED. I. BACKGROUND Plaintiff filed her DIB application in November 2022 alleging that she became disabled beginning April 27, 2022. (R. at 1818–19.) After Plaintiff’s application was denied initially and on reconsideration, an Administrative Law Judge (“ALJ”) held a video hearing on March 5,

2024, at which Plaintiff, who was represented by counsel, appeared and testified. (Id. at 1639–

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. 70.) On April 25, 2024, the ALJ issued an unfavorable determination, which became final on April 21, 2025, when the Appeals Council denied Plaintiff’s request for review. (Id. at 1614–38, 11–17.) Plaintiff seeks judicial review of that unfavorable determination. She raises three related contentions of error. First, Plaintiff contends that the ALJ reversibly erred by determining that

her migraines were a severe medically determinable impairment (“MDI”) but then later inconsistently concluding that her headaches were secondary to other conditions under Social Security Ruling (“SSR”) 19-4p. (Pl.’s Statement of Errors 5–8, ECF No. 9.) Plaintiff next contends that the ALJ reversibly erred by failing to properly determine if her migraines medically equaled Listing 11.02 under SSR 19-4p. (Id. at 8–14.) Plaintiff finally contends that the ALJ reversibly erred because his residual functional capacity (“RFC”) 2 determination did not adequately account for her migraines. (Id. at 14–19.) II. THE ALJ’S DECISION The ALJ issued the unfavorable determination on April 25, 2024. (R. at 1614–38.) He initially determined that Plaintiff met the insured status requirements through December 31,

2 A claimant’s RFC is an assessment of “the most [she] can still do despite [her] limitations” “on a regular and continuing basis.” 20 C.F.R. § 404.1545(a)(1), (b)–(c). 2027. (Id. at 1619.) At step one of the sequential evaluation process,3 the ALJ found that Plaintiff had not engaged in substantial gainful activity since her alleged onset date of April 27, 2022. (Id.) At step two, the ALJ found that Plaintiff had the following severe MDIs: obesity; fibromyalgia; migraine headaches; carpel tunnel syndrome; depression; an anxiety disorder; and attention deficit hyperactivity disorder (ADHD). (Id. at 1620.) 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. Part 404, Subpart P, Appendix 1. (Id.) The ALJ then set forth Plaintiff’s RFC as follows: After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) subject to the following limitations: (1) occasional crouching, crawling, kneeling, stooping, balancing, and climbing of ramps and stairs; (2) no

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). climbing of ladders, ropes, and scaffolds; (3) no work around hazards such as unprotected heights or dangerous machinery; (4) frequent use of the hands for handling and fingering; (5) simple, routine, repetitive tasks; (6) occasional superficial contact with co-workers and supervisors (superficial contact is defined as able to receive simple instructions, ask simple questions, and receive performance appraisals but as unable to engage in more complex social interactions such as persuading other people or resolving superficial conflicts); (7) no public contact; (7) no fast paced work; (8) no strict production quotas; (9) very little, if any change in the job duties or the work routine from one day to the next and in which any changes could be explained.

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Lisa P. v. Commissioner of Social Security, (S.D. Ohio 2026).

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