Sanchez v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedDecember 19, 2023
Docket3:23-cv-00016
StatusUnknown

This text of Sanchez v. Commissioner of Social Security (Sanchez 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
Sanchez v. Commissioner of Social Security, (S.D. Ohio 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

KELLY S.1,

Plaintiff,

v. Civil Action 3:23-cv-16 Judge Michael J. Newman COMMISSIONER OF SOCIAL Magistrate Judge Chelsey M. Vascura SECURITY,

Defendant.

REPORT AND RECOMMENDATION Plaintiff, Kelly S., (“Plaintiff”), brings this action under 42 U.S.C. § 405(g) for review of a final decision of the Commissioner of Social Security (“Commissioner”) denying her application for Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”). This matter is before the undersigned for a Report and Recommendation on Plaintiff’s Statement of Errors (ECF No. 8), the Commissioner’s Memorandum in Opposition (ECF No. 9), Plaintiff’s Reply Memorandum (ECF No. 10), and the administrative record (ECF No. 7). For the reasons that follow, the undersigned RECOMMENDS that the Court AFFIRM the Commissioner of Social Security’s non-disability determination and OVERRULE Plaintiff’s Statement of Errors. I. BACKGROUND Plaintiff protectively filed her application for Title II disability insurance benefits and for Title XVI supplemental security income benefits on February 10, 2020, alleging that she became

1 Pursuant to this Court’s General Order 22-01, any opinion, order, judgment, or other disposition in Social Security cases shall refer to plaintiffs by their first names and last initials. disabled on January 17, 2020. Plaintiff’s applications were denied at the initial and reconsideration levels. An administrative law judge (“ALJ”) held a telephone hearing on August 31, 2021. Plaintiff was represented by counsel, and an impartial vocational expert (“VE”) also appeared. Additional medical records were entered into the record following the hearing, and the ALJ issued an unfavorable determination on December 22, 2021. That unfavorable

determination became final on February 11, 2022, when the Appeals Council denied Plaintiff’s request for review. Plaintiff seeks judicial review of that final determination. Plaintiff asserts two contentions of error: (1) the ALJ erred in evaluating the severity of her mental health impairments and failing to include any limitations related to mental health in Plaintiff’s residual functional capacity (“RFC”); and (2) the ALJ erred in evaluating medical opinion evidence when determining Plaintiff’s RFC. (Pl.’s Statement of Errors 5–19, ECF No. 8). These contentions of error lack merit. II. THE ALJ’S DECISION

On December 22, 2021, the ALJ issued her decision. The ALJ first determined that Plaintiff met the insured status requirements of the Social Security Act through September 30, 2024. (R. 19.) At step one of the sequential evaluation process,2 the ALJ found that Plaintiff had not engaged in substantially gainful activity since the alleged onset date of January 17, 2020. (Id.) At step two, the ALJ found that Plaintiff had the severe impairments of degenerative changes of the cervical sand lumbar spine, spondylosis, osteoarthritis left shoulder, bilateral plantar fasciitis, sensory and diabetic polyneuropathy, diabetes, peptic ulcer, gastritis,

osteoarthritis of the bilateral knees, and ganglion cyst left wrist. (Id.) In addition, the ALJ found that Plaintiff’s depressive and anxiety disorders were medically determinable, but that they were not severe. (Id. at 20–21.) The ALJ then set forth Plaintiff’s RFC3 as follows: After careful consideration of the entire record, I find that [Plaintiff] has the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) and 416.967(b) except she can lift/carry 20 pounds occasionally and 10 pounds frequently. She can sit 6 hours and stand/walk 6 hours in an 8-hourwork [sic] day, with normal breaks. She can never climb ladders, ropes, or scaffolds and can occasionally climb ramps and stairs. She can frequently balance as defined by the Selected Characteristics of Occupations (SCO). The [Plaintiff] can occasionally stoop, kneel, and [crouch] but never crawl. [Plaintiff] can frequently reach, handle, and finger with her bilateral upper extremity. The [Plaintiff] can have only

2 Social Security Regulations require ALJs to resolve a disability claim through a five-step sequential evaluation of the evidence. See 20 C.F.R. § 404.1520(a)(4). Although a dispositive finding at any step terminates the ALJ’s review, see Colvin v. Barnhart, 475 F.3d 727, 730 (6th Cir. 2007), if fully considered, the sequential review considers and answers five questions: 1. Is the claimant engaged in substantial gainful activity? 2. Does the claimant suffer from one or more severe impairments? 3. Do the claimant’s severe impairments, alone or in combination, meet or equal the criteria of an impairment set forth in the Commissioner’s Listing of Impairments, 20 C.F.R. Subpart P, Appendix 1? 4. Considering the claimant’s residual functional capacity, can the claimant perform his or her past relevant work? 5. Considering the claimant’s age, education, past work experience, and residual functional capacity, can the claimant perform other work available in the national economy? See 20 C.F.R. § 404.1520(a)(4); see also Henley v. Astrue, 573 F.3d 263, 264 (6th Cir. 2009); Foster v. Halter, 279 F.3d 348, 354 (6th Cir. 2001). 3 A claimant’s RFC is an assessment of “the most [she] can still do despite [her] limitations.” 20 C.F.R. §§ 404.1545(a)(1); 416.945(a)(1). occasional exposure to vibration. She is unable to work at unprotected heights or in the vicinity of uncovered unguarded moving machinery. She can frequently rotate her neck.

(Id. at 23–24.) At step four, the ALJ relied on testimony from a vocational expert to determine that Plaintiff was able to perform her past relevant work as a Mail Sorter and Security Guard. (Id. at 27.) The ALJ therefore concluded that Plaintiff had not been under a disability, as defined in the Social Security Act, from January 17, 2020, through the date of the ALJ’s determination. (Id. at 28.) III. STANDARD OF REVIEW When reviewing a case under the Social Security Act, the Court “must affirm a decision by the Commissioner as long as it is supported by substantial evidence and was made pursuant to proper legal standards.” DeLong v. Comm’r of Soc. Sec., 748 F.3d 723, 726 (6th Cir. 2014) (cleaned up); see also 42 U.S.C. § 405(g) (“The findings of the Commissioner of Social Security as to any fact, if supported by substantial evidence, shall be conclusive . . . .”). While this standard “requires more than a mere scintilla of evidence, substantial evidence means only such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Moats v. Comm’r of Soc. Sec., 42 F.4th 558, 561 (6th Cir. 2022) (cleaned up) (quoting Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019)). Although the substantial evidence standard is deferential, it is not trivial. The Court must “examine[ ] the record as a whole and take[ ] into account whatever in the record fairly detracts

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Sanchez v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanchez-v-commissioner-of-social-security-ohsd-2023.