Moore v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedFebruary 14, 2025
Docket2:24-cv-00204
StatusUnknown

This text of Moore v. Commissioner of Social Security (Moore 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
Moore v. Commissioner of Social Security, (S.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

JOHN M.1, Case No. 2:24-cv-204 Plaintiff, Litkovitz, M.J.

vs.

COMMISSIONER OF ORDER SOCIAL SECURITY, Defendant. Plaintiff John M. brings this action under 42 U.S.C. § 405(g) for judicial review of the final decision of the Commissioner of Social Security (Commissioner) denying his application for disability insurance benefits (DIB). This matter is before the Court on plaintiff’s Statement of Errors (Doc. 9), the Commissioner’s response in opposition (Doc. 10), and plaintiff’s reply memorandum (Doc. 11). I. Procedural Background Plaintiff filed an application for DIB on September 19, 2019, alleging an onset date of disability of June 1, 2015, due to left side facial pain, fatigue, stomach pain/nausea, upper back, neck, and shoulder pain, lower back and waist tenderness, and high triglycerides. (Tr. 270-71, see also Tr. 338). The application was denied initially and upon reconsideration. Plaintiff, through counsel, requested and was granted a de novo telephone hearing before administrative law judge (ALJ) Frederick Andreas. Plaintiff and a vocational expert (VE) appeared and testified at the hearing on January 12, 2021. (Tr. 70-97). On February 2, 2021, the ALJ issued a decision,

1 Pursuant to General Order 22-01, due to significant privacy concerns in social security cases, any opinion, order, judgment or other disposition in social security cases in the Southern District of Ohio shall refer to plaintiffs only by their first names and last initials. concluding that plaintiff was not disabled. (Tr. 121-39). The Appeals Council granted plaintiff’s request for review and remanded the matter for further proceedings. (Tr. 140-46). On remand, the claim was assigned to the same ALJ. After an October 6, 2022 telephone hearing (Tr. 39-69), the ALJ issued a decision on December 7, 2022, again denying plaintiff’s

application (Tr. 14-38). This decision became the final decision of the Commissioner when the Appeals Council denied review on December 4, 2023. (Tr. 1-6). II. Analysis A. Legal Framework for Disability Determinations To qualify for disability benefits, a claimant must suffer from a medically determinable physical or mental impairment that can be expected to result in death or that has lasted or can be expected to last for a continuous period of not less than 12 months. 42 U.S.C. § 423(d)(1)(A). The impairment must render the claimant unable to engage in the work previously performed or in any other substantial gainful employment that exists in the national economy. 42 U.S.C. §§ 423(d)(2), 1382c(a)(3)(B).

Regulations promulgated by the Commissioner establish a five-step sequential evaluation process for disability determinations: 1) If the claimant is doing substantial gainful activity, the claimant is not disabled.

2) If the claimant does not have a severe medically determinable physical or mental impairment – i.e., an impairment that significantly limits his or her physical or mental ability to do basic work activities – the claimant is not disabled.

3) If the claimant has a severe impairment(s) that meets or equals one of the listings in Appendix 1 to Subpart P of the regulations and meets the duration requirement, the claimant is disabled.

4) If the claimant’s impairment does not prevent him or her from doing his or her past relevant work, the claimant is not disabled. 5) If the claimant can make an adjustment to other work, the claimant is not disabled. If the claimant cannot make an adjustment to other work, the claimant is disabled.

Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647, 652 (6th Cir. 2009) (citing 20 C.F.R. §§ 404.1520(a)(4)(i)-(v), 404.1520(b)-(g)). The claimant has the burden of proof at the first four steps of the sequential evaluation process. Id.; Wilson v. Comm’r of Soc. Sec., 378 F.3d 541, 548 (6th Cir. 2004). Once the claimant establishes a prima facie case by showing an inability to perform the relevant previous employment, the burden shifts to the Commissioner to show that the claimant can perform other substantial gainful employment and that such employment exists in the national economy. Rabbers, 582 F.3d at 652; Harmon v. Apfel, 168 F.3d 289, 291 (6th Cir. 1999). B. The Administrative Law Judge’s Findings The ALJ applied the sequential evaluation process and made the following findings of fact and conclusions of law: 1. [Plaintiff] last met the insured status requirements of the Social Security Act on December 31, 2020.

2. [Plaintiff] did not engage in substantial gainful activity during the period from his alleged onset date of June 10, 2015 through his date last insured of December 31, 2020 (20 CFR 404.1571 et seq).

3. Through the date last insured, [plaintiff] had the following severe impairments: atypical face pain with differential diagnoses of trigeminal neuralgia, glossopharyngeal neuralgia, and deafferentation pain; and a back disorder (mild degenerative spondylosis of the lumbar spine) (20 CFR 404.1520(c)).

4. Through the date last insured, [plaintiff] did not have an impairment or combination of impairments that met or medically equaled the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1 (20 CFR 404.1520(d), 404.1525 and 404.1526).

5. After careful consideration of the entire record, the [ALJ] finds that, through the date last insured, [plaintiff] had the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) except frequent climbing of ramps, stairs, ladders, ropes, or scaffolds; frequent stooping, crouching, or crawling; must avoid concentrated exposure to loud environments; and must avoid concentrated exposure to hazards such as unprotected heights or operating heavy equipment.

6. Through the date last insured, [plaintiff] was capable of performing past relevant work as a sales person, general hardware. This work did not require the performance of work-related activities precluded by [plaintiff]’s residual functional capacity (20 CFR 404.1565).

7. [Plaintiff] was not under a disability, as defined in the Social Security Act, at any time from June 15, 2015, the alleged onset date, through December 31, 2020, the date last insured (20 CFR 404.1520(g)).

(Tr. 19-30). C. Judicial Standard of Review Judicial review of the Commissioner’s determination is limited in scope by 42 U.S.C.

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