Sands v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedJanuary 25, 2022
Docket1:20-cv-00821
StatusUnknown

This text of Sands v. Commissioner of Social Security (Sands 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.

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Sands v. Commissioner of Social Security, (S.D. Ohio 2022).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

CATHY S.1, Case No. 1:20-cv-821 Plai0Fntiff, Litkovitz, M.J.

vs.

COMMISSIONER OF ORDER SOCIAL SECURITY,

Defendant.

Plaintiff Cathy S. brings this action pursuant to 42 U.S.C. §§ 405(g) and 1383(c)(3) for judicial review of the final decision of the Commissioner of Social Security (Commissioner) denying her application for disability insurance benefits (DIB). This matter is before the Court on plaintiff’s Statement of Errors (Doc. 16), the Commissioner’s response (Doc. 21), and plaintiff’s reply (Doc. 22). I. Procedural Background Plaintiff filed her application for DIB in July 2016 alleging disability since August 11, 2011 (Tr. 201), due to epilepsy, type II diabetes mellitus, chronic obstructive pulmonary disease (COPD), tendonitis, high blood pressure, and bronchitis (Tr. 243). The application was denied initially and upon reconsideration. Plaintiff, through counsel, requested and was granted a de novo hearing before administrative law judge (ALJ) Stuart Adkins on May 15, 2019. Plaintiff and a vocational expert (VE) appeared and testified at the ALJ hearing. (Tr. 28-67). On August

1 The Committee on Court Administration and Case Management of the Judicial Conference of the United States has recommended that, due to significant privacy concerns in social security cases, federal courts should refer to claimants only by their first names and last initials. 14, 2019, the ALJ issued a decision finding plaintiff was disabled as of July 15, 2016, but not prior to this date. (Tr. 115-35). The Appeals Council granted plaintiff’s request for review and found that plaintiff was “entitled to a period of disability beginning on July 15, 2016, and to disability insurance benefits under sections 216(i) and 223, respectively, of the Social Security Act.” (Tr. 11). In so doing, the Appeals Council specifically adopted the ALJ’s “statements regarding the pertinent

provisions of the Social Security Act, Social Security Administration Regulations, Social Security Rulings and Acquiescence Rulings, the issues in the case, and the evidentiary facts, as applicable”; his “findings or conclusions regarding whether the claimant is disabled for the period July 15, 2016”; his conclusions regarding plaintiff’s “statements concerning the alleged symptoms”; and affirmed his “findings and conclusions at Steps 1 through 5 of the sequential evaluation process. . . .” (Tr. 8-9). This matter is properly before this Court for review. II. Analysis A. Legal Framework for Disability Determinations To qualify for disability benefits, a claimant must suffer from a medically determinable physical or mental impairment that can be expected to result in death or that has lasted or can be

expected to last for a continuous period of not less than 12 months. 42 U.S.C. § 423(d)(1)(A). The impairment must render the claimant unable to engage in the work previously performed or in any other substantial gainful employment that exists in the national economy. 42 U.S.C. § 423(d)(2).

2 Regulations promulgated by the Commissioner establish a five-step sequential evaluation process for disability determinations: 1) If the claimant is doing substantial gainful activity, the claimant is not disabled.

2) If the claimant does not have a severe medically determinable physical or mental impairment – i.e., an impairment that significantly limits his or her physical or mental ability to do basic work activities – the claimant is not disabled.

3) If the claimant has a severe impairment(s) that meets or equals one of the listings in Appendix 1 to Subpart P of the regulations and meets the duration requirement, the claimant is disabled.

4) If the claimant’s impairment does not prevent him or her from doing his or her past relevant work, the claimant is not disabled.

5) If the claimant can make an adjustment to other work, the claimant is not disabled. If the claimant cannot make an adjustment to other work, the claimant is disabled.

Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647, 652 (6th Cir. 2009) (citing 20 C.F.R. §§ 404.1520(a)(4)(i)-(v), 404.1520(b)-(g)). The claimant has the burden of proof at the first four steps of the sequential evaluation process. Id.; Wilson v. Comm’r of Soc. Sec., 378 F.3d 541, 548 (6th Cir. 2004). Once the claimant establishes a prima facie case by showing an inability to perform the relevant previous employment, the burden shifts to the Commissioner to show that the claimant can perform other substantial gainful employment and that such employment exists in the national economy. Rabbers, 582 F.3d at 652; Harmon v. Apfel, 168 F.3d 289, 291 (6th Cir. 1999).

3 B. The Administrative Law Judge’s Findings The ALJ applied the sequential evaluation process and made the following findings of fact and conclusions of law: 1. [Plaintiff] meets the insured status requirements of the Social Security Act through December 31, 2016.

2. [Plaintiff] has not engaged in substantial gainful activity since the alleged onset date (20 CFR 404.1571 et seq.).

3. Since the alleged onset date of disability, August 11, 2011, [plaintiff] has had the following severe impairments: obesity, epilepsy, type II diabetes mellitus, chronic obstructive pulmonary disease (COPD), hypertension, and carpal tunnel syndrome (20 CFR 404.1520(c)).

4. Since August 11, 2011, [plaintiff] has not had an impairment or combination of impairments that meets or medically equals the severity of one of the listed impairments in 20 CFR Part 404, Subpart P, Appendix 1 (20 CFR 404.1520(d), 404.1525 and 404.1526).

5. After careful consideration of the entire record, [the ALJ] finds that prior to July 15, 2016, the date [plaintiff] became disabled, [plaintiff] had the residual functional capacity to perform light work as defined in 20 CFR 404.1567(b) with lifting and/or carrying about twenty pounds occasionally and ten pounds occasionally. She was able to stand and/or walk for about six hours and sit for about six hours in an eight-hour workday. She was able to frequently push and/or pull with the upper extremities. She was limited to no climbing of ladders, ropes, and scaffolds with frequent climbing of ramps and stairs. She was able to frequently handle, finger, and feel bilaterally. [Plaintiff] should avoid concentrated exposure to extreme heat, extreme cold, wetness, humidity, dusts, odors, fumes, and pulmonary irritants. She should also avoid exposure to unprotected heights and dangerous machinery.

6.

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