O'Connor v. Commissioner of Social Security

CourtDistrict Court, W.D. Kentucky
DecidedJune 22, 2023
Docket3:22-cv-00361
StatusUnknown

This text of O'Connor v. Commissioner of Social Security (O'Connor v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, W.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
O'Connor v. Commissioner of Social Security, (W.D. Ky. 2023).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF KENTUCKY LOUISVILLE DIVISION

ANTHONY O., ) ) Plaintiff, ) Civil Action No. 3:22-CV-361-CHB ) v. ) ) KILOLO KIJAKAZI, Commissioner of ) ORDER ADOPTING MAGISTRATE Social Security, ) JUDGE’S REPORT AND ) RECOMMENDATION Defendant. )

*** *** *** *** This matter is before the Court on Magistrate Judge Regina S. Edwards’s Report and Recommendation (“Recommendation”). [R. 25]. The Recommendation addresses Plaintiff Anthony O.’s appeal from the final determination of the Commissioner denying his application for child disability benefits. Plaintiff did not object to Magistrate Judge Edwards’s Recommendation. For the reasons that follow, the Court will adopt the Recommendation and affirm the final decision of the Commissioner. I. Background On May 23, 2019, Marlena O. filed an application for Supplemental Security Income (“SSI”) benefits from the Social Security Administration under Title XVI of the Social Security Act, 42 U.S.C. § 1382c(a)(3) (the “Act”), on behalf of her son, Plaintiff Anthony O., who was then a minor. [R. 10 (Administrative Record) (hereinafter “Administrative Transcript” or “Tr.”), at 204]. The application was denied initially and on reconsideration. [Tr. 68–99]. Upon Plaintiff’s request, a hearing was conducted in Louisville, Kentucky before Administrative Law Judge Candance McDaniel (“ALJ McDaniel”) on February 16, 2021. (Tr. 40–67). Plaintiff reached adult age by the time the administrative hearing was held, and he attended the hearing with his mother and an attorney. Id. ALJ McDaniel issued an unfavorable decision on May 12, 2021. (Tr. 12–39). Because Plaintiff was under the age of 18 when his SSI application was filed,1 ALJ McDaniel began by apply the three-step sequential analysis promulgated by the Commissioner for evaluating a disability claim for a minor claimant, 20 C.F.R. § 416.924(a), and found as follows.

First, Plaintiff has not engaged in substantial gainful activity since May 23, 2019, his application date. [Tr. 20]. Second, prior to reaching age 18, Plaintiff had the severe impairments of autism, anxiety, depression, and asthma. Id. Third, none of Plaintiff’s impairments or combination of impairments met or medically equaled the severity of a listed impairment under 20 C.F.R. Pt. 404, Subpt. P, App’x 1. [Tr. 29]. ALJ McDaniel therefore found that, prior to reaching age 18, Plaintiff was not disabled. Id. Because Plaintiff turned 18 while his claim was pending, ALJ McDaniel continued through the five-step sequential analysis promulgated by the Commissioner for evaluating a disability claim for adults, 20 C.F.R. § 404.1520, Kyle v. Comm’r of Soc. Sec., 609 F.3d 847, 855 (6th Cir.

2010), and noted that while Plaintiff had not developed any new impairments since turning 18, he maintains the severe impairments she previously listed. Id. Still, ALJ McDaniel found that none of those impairments reached or equaled listing level. Id. She then determined that, since reaching adult age, Plaintiff has the residual functional capacity (“RFC”) to perform a full range of work at all exertional levels, with the following non-exertional limitations: [Claimant] should avoid concentrated exposure to temperature extremes involving wetness and humidity as well as concentrated exposure to fumes, odors, dusts, gases, and pulmonary irritants; can understand, remember, and carry out simple and detailed instructions; and can interact occasionally with supervisors and coworkers

1 A claimant under the age of 18 is considered disabled if they have a physical or mental impairment, or combination of impairments, that results in marked and severe functional limitations that have lasted or can be expected to last for a continuous period of not less than 12 months, or can be expected to result in death. See generally 20 C.F.R. § 416.924. but no work in tandem with coworkers and no interaction with the public for task completion.

[Tr. 30]. ALJ McDaniel noted that Plaintiff has no past relevant work, but based on his age, education, and RFC, there are jobs that exist in significant numbers in the national economy that Plaintiff can perform. [Tr. 33]. Based on this evaluation, ALJ McDaniel concluded Plaintiff was not disabled. [Tr. 34]. Plaintiff sought review of ALJ McDaniel’s decision, and the Appeals Council declined review. [Tr. 1]. At that point, the denial became the final decision of the Commissioner, and Plaintiff sought judicial review from this Court. [R. 1]. The Court referred Plaintiff’s case to Magistrate Judge Edwards for consideration and the preparation of a Report and Recommendation pursuant to 28 U.S.C. § 636(b)(1)(B). [R. 13]. After the parties submitted their respective briefs [R. 14]; [R. 15], Magistrate Judge Edwards issued her Recommendation on June 2, 2023, recommending that the final decision of the Commissioner be affirmed. [R. 25]. Judicial review of the Commissioner’s decision is restricted to determining whether it is supported by substantial evidence and was made pursuant to proper legal standards. Colvin v. Barnhart, 475 F.3d 727, 729–30 (6th Cir. 2007). “Substantial evidence” is defined as “more than a scintilla of evidence but less than a preponderance; it is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Cutlip v. Sec’y of Health & Hum. Servs., 25 F.3d 284, 286 (6th Cir. 1994). Courts are not to conduct a de novo review, resolve conflicts in the evidence, or make credibility determinations. Id. Rather, the Court must “affirm the

Commissioner’s conclusions unless the Commissioner failed to apply the correct legal standard or made findings of fact that are unsupported by substantial evidence.” McClanahan v. Comm’r of Soc. Sec., 474 F.3d 830, 833 (6th Cir. 2006). Magistrate Judge Edwards accurately recited this standard before addressing each of Plaintiff’s arguments concerning ALJ McDaniel’s decision. First addressing Plaintiff’s contention that ALJ McDaniel violated Social Security Ruling 00-4p, which requires an administrative law judge to identify, address, and explain the resolution of “apparent” conflicts between the testimony of a vocational expert and the contents of the Dictionary of Occupational Titles (“DOT”),

Magistrate Judge Edwards determined that the conflict at issue was not apparent and that, even if it had been, ALJ McDaniel did not err in relying on the vocational expert’s testimony. [R. 25, pp. 5–9]. Indeed, an administrative law judge is not required “to conduct an independent investigation into the testimony of witnesses to determine if they are correct” nor “explain how the conflict was resolved.” Martin v. Comm’r of Soc. Sec., 170 F. App’x 369, 374 (6th Cir. 2006).

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O'Connor v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/oconnor-v-commissioner-of-social-security-kywd-2023.