Minerd v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedJanuary 13, 2022
Docket3:20-cv-00240
StatusUnknown

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

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION AT DAYTON

MARGARET M.,1 : Case No. 3:20-cv-240 : Plaintiff, : Magistrate Judge Peter B. Silvain, Jr. : (by full consent of the parties) vs. : : COMMISSIONER OF THE SOCIAL : SECURITY ADMINISTRATION, : : Defendant. :

DECISION AND ENTRY

Plaintiff Margaret M. brings this case challenging the Social Security Administration’s denial of her application for Supplemental Security Income (SSI). This case is before the Court upon Plaintiff’s Statement of Errors (Doc. #9), the Commissioner’s Memorandum in Opposition (Doc. #10), and the administrative record (Doc. #8). I. Background The Social Security Administration provides 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. § 1382(a). The term “disability” encompasses “any medically determinable physical or mental impairment” that precludes an applicant from performing “substantial gainful activity.” 42 U.S.C. § 1382c(a)(3)(A); see Bowen, 476 U.S. at 469- 70.

1 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 plaintiffs only by their first names and last initials. See also S.D. Ohio General Rule 22-01. In the present case, Plaintiff applied for benefits on October 26, 2016, alleging disability due to several impairments, including bipolar disorder, Crohn’s Disease, joint pain, rashes, depression, sacroiliitis, anxiety, limited education, arthritis, and ankylosing spondylitis. (Doc. #8, PageID #280). After Plaintiff’s application was denied initially and upon reconsideration, she requested and received a hearing before Administrative Law Judge (ALJ) Stuart Adkins. Thereafter, the ALJ issued a written decision, addressing each of the five sequential steps set forth in the Social Security Regulations. See 20 C.F.R. § 416.920. He reached the following main conclusions: Step 1: Plaintiff has not engaged in substantial gainful employment since October 26, 2016, the application date.

Step 2: She has the severe impairments of Crohn’s Disease; degenerative disc disease of the lumbar spine; osteoarthritis; bipolar disorder/depression; and anxiety disorder.

Step 3: She does not have an impairment or combination of impairments that meets or equals the severity of one in the Commissioner’s Listing of Impairments, 20 C.F.R. Part 404, Subpart P, Appendix 1.

Step 4: Her residual functional capacity, or the most she could do despite her impairments, see Howard v. Comm’r of Soc. Sec., 276 F.3d 235, 239 (6th Cir. 2002), consists of “light work … subject to the following limitations: (1) would alternate between sitting and standing every 30 minutes while at the workstation; (2) can never climb ladders, ropes and scaffolds; (3) can occasionally climb ramps and stairs, stoop, kneel, crouch, and crawl; ([4]) should avoid unprotected heights, dangerous machinery, and commercial driving; ([5]) can perform simple, routine tasks but not at a production-rate pace and not with strict production standards; ([6]) can have occasional interaction with supervisors, co-workers and the general public; ([7]) no jobs requiring teamwork or tandem tasks; and ([8]) can tolerate occasional changes to a routine work setting defined as 1-2 per week.”

She has no past relevant work.

Step 5: She could perform a significant number of jobs that exist in the national economy. 2 (Doc. #8-2, PageID #s 34-45). Based on these findings, the ALJ concluded that Plaintiff was not under a benefits-qualifying disability. Id. at 45. The evidence of record is adequately summarized in the ALJ’s decision (Doc. #8-2, PageID #s 35-37, 40-43), Plaintiff’s Statement of Errors (Doc. #9), and the Commissioner’s Memorandum in Opposition (Doc. #10). To the extent that additional facts are relevant, they will be summarized in the discussion section below. II. Standard of Review Judicial review of an ALJ’s decision is limited to whether the ALJ’s findings are supported by substantial evidence and whether the ALJ applied the correct legal standards. Blakley v. Comm’r of Soc. Sec., 581 F.3d 399, 406 (6th Cir. 2009); see Bowen v. Comm’r of Soc. Sec., 478 F.3d 742, 745-46 (6th Cir. 2007). Substantial evidence is such “relevant evidence that a reasonable mind might accept as adequate to support a conclusion.” Gentry v. Comm’r of Soc. Sec., 741 F.3d 708, 722 (6th Cir. 2014) (citing Rogers v. Comm’r of Soc. Sec., 486 F.3d 234, 241 (6th Cir. 2007)). It is

“less than a preponderance but more than a scintilla.” Id. The second judicial inquiry—reviewing the correctness of the ALJ’s legal analysis—may result in reversal even if the ALJ’s decision is supported by substantial evidence in the record. Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647, 651 (6th Cir. 2009). Under this review, “a decision of the Commissioner will not be upheld where the [Social Security Administration] fails to follow its own regulations and where that error prejudices a claimant on the merits or deprives the claimant of a substantial right.” Bowen, 478 F.3d at 746 (citing Wilson v. Comm’r of Soc. Sec., 378 F.3d 541, 546-47 (6th Cir. 2004)). III. Discussion 3 In her Statement of Errors, Plaintiff raises three challenges to the ALJ’s decision. (Doc. # 9, PageID #s 1856-63). Specifically, Plaintiff contends that ALJ Adkins (1) incorrectly identified severe impairments under prong two of the sequential process; (2) failed to follow the treating physician rule and give deferential weight to Plaintiff’s treating physicians’ opinions; and (3) failed to fully consider essential vocational expert testimony. Id. According to Plaintiff, each of these reasons support a finding that this matter should be remanded. Id. In response, the Commissioner maintains that substantial evidence supports the ALJ’s decision and should, therefore, be affirmed. (Doc. #10, PageID #s 1868-87). A. Plaintiff’s Severe Impairments

In her first statement of error, Plaintiff contends that the ALJ incorrectly identified severe impairments under step two of the sequential process. (Doc.# 9, PageID #1856). In response, the Commissioner points out that ALJ Adkins did, in fact, find that Plaintiff had severe mental health impairments, including bipolar disorder, depression, and anxiety disorder and provided significant mental limitations in Plaintiff’s residual functional capacity (RFC) that reasonably accounted for these restrictions. (Doc. #10, PageID #s 1868-70).

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Related

Bowen v. City of New York
476 U.S. 467 (Supreme Court, 1986)
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Minerd v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/minerd-v-commissioner-of-social-security-ohsd-2022.