Sandrock v. Commissioner of Social Security

CourtDistrict Court, W.D. Michigan
DecidedFebruary 4, 2025
Docket1:24-cv-00017
StatusUnknown

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

Bluebook
Sandrock v. Commissioner of Social Security, (W.D. Mich. 2025).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

CHARLES SANDROCK,

Plaintiff, Hon. Hala Y. Jarbou v. Case No. 1:24-cv-00017 COMMISSIONER OF SOCIAL SECURITY,

Defendant. _________________________________/

REPORT AND RECOMMENDATION This is an action pursuant to Section 205(g) of the Social Security Act, 42 U.S.C. § 405(g), to review a final decision of the Commissioner of Social Security denying Plaintiff’s claim for Disability Insurance Benefits (DIB) and Supplemental Security Income under Titles II and XVI of the Social Security Act. Section 405(g) limits the Court to a review of the administrative record and provides that if the Commissioner’s decision is supported by substantial evidence, it shall be conclusive. Pursuant to 28 U.S.C. § 636(b)(1)(B), the undersigned recommends that the Commissioner’s decision be affirmed. STANDARD OF REVIEW The Court’s jurisdiction is confined to a review of the Commissioner’s decision and of the record made in the administrative hearing process. See Willbanks v. Sec’y of

Health and Human Services, 847 F.2d 301, 303 (6th Cir. 1988). The scope of judicial review in a social security case is limited to determining whether the Commissioner applied the proper legal standards in making her decision and whether there exists in the record substantial evidence supporting that decision. See Brainard v. Sec’y of Health and Human Services, 889 F.2d 679, 681 (6th Cir. 1989). The Court may not conduct a de novo review of the case, resolve evidentiary conflicts, or decide questions of credibility. See Garner v. Heckler, 745 F.2d 383, 387 (6th

Cir. 1984). It is the Commissioner who is charged with finding the facts relevant to an application for disability benefits, and her findings are conclusive provided they are supported by substantial evidence. See 42 U.S.C. § 405(g). Substantial evidence is more than a scintilla, but less than a preponderance. See Cohen v. Sec’y of Dep’t of Health and Human Services, 964 F.2d 524, 528 (6th Cir. 1992) (citations omitted). It is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. See

Richardson v. Perales, 402 U.S. 389, 401 (1971); Bogle v. Sullivan, 998 F.2d 342, 347 (6th Cir. 1993). In making this determination, the Court must consider the evidence on the record as a whole and take into account whatever in the record fairly detracts from its weight. See Richardson v. Sec’y of Health and Human Services, 735 F.2d 962, 963 (6th Cir. 1984).

2 As has been widely recognized, the substantial evidence standard presupposes the existence of a zone within which the decision maker can properly rule either way, without judicial interference. See Mullen v. Bowen, 800 F.2d 535, 545 (6th Cir. 1986)

(citation omitted). This standard affords to the administrative decision maker considerable latitude and indicates that a decision supported by substantial evidence will not be reversed simply because the evidence would have supported a contrary decision. See Bogle, 998 F.2d at 347; Mullen, 800 F.2d at 545. BACKGROUND

Plaintiff was 44 years of age on his alleged disability onset date. (ECF No. 5- 16, PageID.1152). Plaintiff possesses a high school education and worked previously as a forklift driver and a lead baker. (ECF No. 9, PageID.1592). Plaintiff applied for benefits on July 13, 2018, alleging that he had been disabled since October 20, 2014, due to chronic pain syndrome, diabetes mellitus, and other ailments. (ECF No. 5-16, PageID.1147-48). Plaintiff’s application was denied initially on October 10, 2018, after which he

requested a hearing before an Administrative Law Judge (ALJ). The ALJ, in an opinion dated November 20, 2019, determined that Plaintiff did not qualify for disability benefits. (ECF No. 5-2, PageID.31-40). On September 13, 2022, the U.S. District Court for the Western District of Michigan reviewed the ALJ’s determination and remanded for further consideration of certain medical opinions. (ECF No. 5-16, PageID.1145). The ALJ, in an opinion dated October 19, 2023, again determined that

Plaintiff did not qualify for disability benefits. (Id. at PageID.1154). The Appeals Council declined to review the ALJ’s determination, rendering it the Commissioner’s final decision in the matter. Plaintiff subsequently initiated this action pursuant to 42 U.S.C. § 405(g), seeking judicial review of the ALJ’s decision.

ANALYSIS OF THE ALJ’S DECISION The social security regulations articulate a five-step sequential process for evaluating disability. See 20 C.F.R. §§ 404.1520(a-f), 416.920(a-f). If the Commissioner can make a dispositive finding at any point in the review, no further finding is required. See 20 C.F.R. §§ 404.1520(a), 416.920(a). The regulations also

provide that, if a claimant suffers from a non-exertional impairment as well as an exertional impairment, both are considered in determining his residual functional capacity. See 20 C.F.R. §§ 404.1545, 416.945. Plaintiff bears the burden to demonstrate he is entitled to disability benefits and he satisfies his burden by demonstrating that his impairments are so severe that he is unable to perform his previous work, and cannot, considering his age, education, and work experience, perform any other substantial gainful employment existing in

significant numbers in the national economy. See 42 U.S.C. § 423(d)(2)(A). While the burden of proof shifts to the Commissioner at step five of the sequential evaluation process, Plaintiff bears the burden of proof through step four of the procedure, the point at which his residual functioning capacity (RFC) is determined. O’Neal v. Comm’r of Soc. Sec., 799 Fed. Appx. 313, 315 (6th Cir., Jan. 7, 2020). The ALJ determined that Plaintiff suffers from degenerative disc disease,

moderate thoracic spondylosis, and diabetes mellitus without complication, severe impairments that whether considered alone or in combination with other impairments, failed to satisfy the requirements of any impairment identified in the Listing of Impairments detailed in 20 C.F.R., Part 404, Subpart P, Appendix 1. (ECF

No. 5-16, PageID.1148).

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Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
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Doris Poe v. Commissioner of Social Security
342 F. App'x 149 (Sixth Circuit, 2009)
Brooke Taskila v. Comm'r of Social Security
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