Phillips v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedMarch 26, 2021
Docket3:19-cv-00318
StatusUnknown

This text of Phillips v. Commissioner of Social Security (Phillips 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
Phillips v. Commissioner of Social Security, (S.D. Ohio 2021).

Opinion

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

CONNIE L. PHILLIPS, : Case No. 3:19-cv-318 : Plaintiff, : : Magistrate Judge Sharon L. Ovington vs. : (by full consent of the parties) : COMMISSIONER OF THE SOCIAL : SECURITY ADMINISTRATION, : : Defendant. :

DECISION AND ENTRY

I. Introduction Plaintiff Connie L. Phillips filed an application for Disability Insurance Benefits and Supplemental Security Income in April 2009. Her claim was denied initially and upon reconsideration. She requested a hearing, and after that hearing, Administrative Law Judge (ALJ) Paul R. Armstrong issued a decision finding that Plaintiff was not under a “disability” as defined in the Social Security Act. The Appeals Council granted Plaintiff’s request for review and remanded the case. After a second hearing at Plaintiff’s request, Administrative Law Judge Gregory G. Kenyon issued an unfavorable decision finding that Plaintiff was not under a “disability” as defined in the Social Security Act. The Appeals Council denied Plaintiff’s request for review. She subsequently filed an action before this Court. At the parties’ request, this Court ordered that the matter be remanded to the Commissioner for further proceedings. On remand, the case returned to ALJ Kenyon. Plaintiff requested a third hearing. After that hearing, ALJ Kenyon again concluded Plaintiff was not eligible for benefits because she was not under a “disability” as defined in the Social Security Act. The Appeals

Council denied Plaintiff’s request for review. Plaintiff then filed the present action before this Court, and now seeks a remand for benefits, or in the alternative, for further proceedings. The Commissioner asks the Court to affirm the non-disability decision. The case is presently before the Court upon Plaintiff’s Statement of Errors (Doc. No. 9), the Commissioner’s Memorandum in Opposition (Doc. No. 12), Plaintiff’s Reply

(Doc. No. 13) and the administrative record (Doc. No. 8). II. Background Plaintiff asserts that she has been under a disability since July 10, 1993. On the alleged disability onset date, she was twenty-one years old. At that time, Plaintiff was considered a “younger individual” under Social Security Regulations and has remained a

“younger individual” at all times relevant to this case. See § 404.1563(c); 20 C.F.R. § 416.963(c).1 She has a limited education. The evidence of the record is sufficiently summarized in the ALJ’s decision (Doc. No. 8-10, Page ID 1091-1108), Plaintiff’s Statement of Errors (Doc. No. 9), the Commissioner’s Memorandum in Opposition (Doc. No. 12), and Plaintiff’s Reply (Doc.

No. 13). Rather than repeat these summaries, the Court will focus on the pertinent evidence in the discussion below.

1 The remaining citations will identify the pertinent Disability Insurance Benefits Regulations with full knowledge of the corresponding Supplemental Security Income Regulations. III. Standard of Review The Social Security Administration provides Disability Insurance Benefits and 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. §§ 423(a)(1), 1382(a). The term “disability”—as defined by the Social Security Act—has specialized meaning of limited scope. It encompasses “any medically determinable physical or mental impairment” that precludes an applicant from performing a significant paid job—i.e., “substantial gainful activity,” in Social Security lexicon. 42

U.S.C. §§ 423(d)(1)(A), 1382c(a)(3)(A); see Bowen, 476 U.S. at 469-70. Judicial review of an ALJ’s non-disability decision proceeds along two lines: “whether the ALJ applied the correct legal standards and whether the findings of the ALJ are supported by substantial evidence.” Blakely 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).

Review for substantial evidence is not driven by whether the Court agrees or disagrees with the factual findings or by whether the administrative record contains evidence contrary to those factual findings. Gentry v. Comm’r of Soc. Sec., 741 F.3d 708, 722 (6th Cir. 2014); Rogers v. Comm’r of Soc. Sec., 486 F.3d 234, 241 (6th Cir. 2007). Instead, the factual findings are upheld if the substantial-evidence standard is met—that is, “if a ‘reasonable

mind might accept the relevant evidence as adequate to support a conclusion.’” Blakely, 581 F.3d at 407 (quoting Warner v. Comm’r of Soc. Sec., 375 F.3d 387, 390 (6th Cir. 2004)). Substantial evidence consists of “more than a scintilla of evidence but less than a preponderance…” Rogers, 486 F.3d at 241 (citations and internal quotation marks omitted); see Gentry, 741 F.3d at 722. The other line of judicial inquiry—reviewing the correctness of the legal criteria— may result in reversal even when the record contains substantial evidence supporting the

factual findings. Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647, 651 (6th Cir. 2009); see Bowen, 478 F.3d at 746. “[E]ven if supported by substantial evidence, ‘a decision of the Commissioner will not be upheld where the SSA fails to follow its own regulations and where that error prejudices a claimant on the merits or deprives the claimant of a substantial right.’” Rabbers, 582 F.3d at 651 (quoting in part Bowen, 478 F.3d at 746, and citing

Wilson v. Comm’r of Soc. Sec., 378 F.3d 541, 546-47 (6th Cir. 2004)). IV. The ALJ’s Decision As noted previously, the Administrative Law Judge was tasked with evaluating the evidence related to Plaintiff’s application for benefits. In doing so, the Administrative Law Judge considered 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 March 23, 2007.

Step 2: She has the severe impairments of degenerative disc disease of the lumbar spine, arthritis of the left knee, asthma, chronic obstructive pulmonary disease (COPD), bipolar disorder, depression, anxiety, post- traumatic stress disorder (PTSD), and a history of polysubstance abuse.

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 (RFC), or the most she could do despite her impairments, see Howard v. Comm’r of Soc. Sec., 276 F.3d 235

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Related

Bowen v. City of New York
476 U.S. 467 (Supreme Court, 1986)
Yer Her v. Commissioner of Social Security
203 F.3d 388 (Sixth Circuit, 1999)
Jimmie L. Howard v. Commissioner of Social Security
276 F.3d 235 (Sixth Circuit, 2002)
Gary Warner v. Commissioner of Social Security
375 F.3d 387 (Sixth Circuit, 2004)
Robert M. Wilson v. Commissioner of Social Security
378 F.3d 541 (Sixth Circuit, 2004)
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)
Charles Gayheart v. Commissioner of Social Security
710 F.3d 365 (Sixth Circuit, 2013)
Blakley v. Commissioner of Social Security
581 F.3d 399 (Sixth Circuit, 2009)
Gentry v. Commissioner of Social Security
741 F.3d 708 (Sixth Circuit, 2014)
David Hargett v. Comm'r of Soc. Sec.
964 F.3d 546 (Sixth Circuit, 2020)
McGeorge v. Comm'r of Soc. Sec.
309 F. Supp. 3d 514 (S.D. Ohio, 2018)

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