Richard v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedAugust 21, 2020
Docket1:19-cv-00581
StatusUnknown

This text of Richard v. Commissioner of Social Security (Richard 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
Richard v. Commissioner of Social Security, (S.D. Ohio 2020).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

KEVIN RICHARD, Case No. 1:19-cv-581

Plaintiff, McFarland, J. Bowman, M.J. v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

REPORT AND RECOMMENDATION

Plaintiff Kevin Richard filed this Social Security appeal in order to challenge the Defendant’s findings that he is not disabled. See 42 U.S.C. §405(g). Proceeding through counsel, Plaintiff presents three claims of error, all of which the Defendant disputes. For the reasons explained below, I conclude that the ALJ’s finding of non-disability should be REVERSED and REMANDED, because it is not supported by substantial evidence in the administrative record. I. Summary of Administrative Record Plaintiff filed his disability applications in 2014, alleging onset in 2013. (Tr. 170- 79). His claims were denied administratively. (Tr. 1-6, 13-29, 31-54, 79, 103). In November 2017, Plaintiff filed new disability applications (Tr. 719-30), and also appealed his prior denied claims to the district court. (Tr. 624-25). In July 2018, based on a joint remand motion, the court remanded the prior denied claims to the agency under sentence four of 42 U.S.C. § 405(g), for further administrative proceedings. (Tr. 644-45). In October 2018, the Appeals Council vacated the ALJ’s decision on the prior claims, consolidated all of Plaintiff’s claims on remand, and ordered a new hearing and decision. (Tr. 646-50). Plaintiff appeared with counsel and testified at a hearing on February 28, 2019, along with a vocational expert. (Tr. 550-72). An ALJ denied his claims on May 15, 2019. (Tr. 527- 42). Plaintiff now seeks judicial review of the denial of his application for benefits. Plaintiff was born in 1958 and was 55 years old at the time his application was filed. He graduated from high school and has past relevant work as an auto mechanic. He alleges disability based primarily on his mental impairments. Based upon the record and testimony presented at the hearing, the ALJ found that Plaintiff had the following severe impairments: foot drop and status post gunshot wound to the left foot, major depressive disorder (MDD), and obsessive compulsive disorder (OCD). (Tr. 531). The ALJ concluded that none of Plaintiff’s impairments alone or in combination met or medically equaled a listed impairment in 20 C.F.R. Part 404,

Subp. P, Appendix 1. The ALJ determined that Plaintiff retains the following residual functional capacity (“RFC”) to perform a full range of work with the following limitations: He can frequently balance. He can occasionally operate foot pedals with the left lower extremity. He can perform simple, routine, repetitive tasks in an environment where changes are no more than ordinary and routine and can be explained in advance. He cannot perform tandem work or close teamwork. He can not have contact with the general public and can have occasional and superficial contact with coworkers and supervisors with superficial defined as no tandem work, rapid production rate pace, or strict quota environments, and no transaction positions.

(Tr. 534). Based upon the record as a whole including testimony from the vocational expert, and given Plaintiff’s age, education, work experience, and RFC, the ALJ concluded that Plaintiff is unable to perform his past relevant work. Nonetheless, there are jobs that exist in significant numbers in the national economy that he can perform, including such jobs as inspector, sorter, routing clerk and document preparer. Accordingly, the ALJ determined that Plaintiff is not under disability, as defined in the Social Security Regulations, and is not entitled to SSI. Id. The Appeals Council denied Plaintiff’s request for review. Therefore, the ALJ’s decision stands as the Defendant’s final determination. On appeal to this Court, Plaintiff argues that the ALJ erred by: 1) improperly weighing the opinion of Plaintiff’s treating psychiatrist; 2) improperly weighing the findings of the consultative examiner and state agency consultant; and 3) improperly adjudicating this matter because he was not properly appointed. Upon close analysis, I find Plaintiff’s first assigned of error to be well taken and dispositive. II. Analysis A. Judicial Standard of Review

To be eligible for SSI or DIB a claimant must be under a “disability” within the definition of the Social Security Act. See 42 U.S.C. §§423(a), (d), 1382c(a). The definition of the term “disability” is essentially the same for both DIB and SSI. See Bowen v. City of New York, 476 U.S. 467, 469-70 (1986). Narrowed to its statutory meaning, a “disability” includes only physical or mental impairments that are both “medically determinable” and severe enough to prevent the applicant from (1) performing his or her past job and (2) engaging in “substantial gainful activity” that is available in the regional or national economies. See Bowen, 476 U.S. at 469-70 (1986). When a court is asked to review the Commissioner’s denial of benefits, the court’s

first inquiry is to determine whether the ALJ’s non-disability finding is supported by substantial evidence. 42 U.S.C. § 405(g). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971) (additional citation and internal quotation omitted). In conducting this review, the court should consider the record as a whole. Hephner v. Mathews, 574 F.2d 359, 362 (6th Cir. 1978). If substantial evidence supports the ALJ’s denial of benefits, then that finding must be affirmed, even if substantial evidence also exists in the record to support a finding of disability. Felisky v. Bowen, 35 F.3d 1027, 1035 (6th Cir. 1994). As the Sixth Circuit has explained: The Secretary’s findings are not subject to reversal merely because substantial evidence exists in the record to support a different conclusion . . . . The substantial evidence standard presupposes that there is a ‘zone of choice’ within which the Secretary may proceed without interference from the courts. If the Secretary’s decision is supported by substantial evidence, a reviewing court must affirm.

Id. (citations omitted).

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Thomas v. Arn
474 U.S. 140 (Supreme Court, 1986)
Bowen v. City of New York
476 U.S. 467 (Supreme Court, 1986)
Robert M. Wilson v. Commissioner of Social Security
378 F.3d 541 (Sixth Circuit, 2004)
Barbara Combs v. Commissioner of Social Security
459 F.3d 640 (Sixth Circuit, 2006)
Debra Rogers v. Commissioner of Social Security
486 F.3d 234 (Sixth Circuit, 2007)
Blakley v. Commissioner of Social Security
581 F.3d 399 (Sixth Circuit, 2009)
Meece v. Comm Social Security
192 F. App'x 456 (Sixth Circuit, 2006)

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Richard v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/richard-v-commissioner-of-social-security-ohsd-2020.