Schrichten v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedJanuary 19, 2022
Docket1:20-cv-00661
StatusUnknown

This text of Schrichten v. Commissioner of Social Security (Schrichten 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
Schrichten v. Commissioner of Social Security, (S.D. Ohio 2022).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION SHAUNA S.1, Case No. 1:20-cv-661 Plaintiff, Litkovitz, M.J. vs. COMMISSIONER OF ORDER SOCIAL SECURITY, Defendant. Plaintiff Shauna 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 plaintiff’s applications for disability insurance benefits (DIB) and supplemental security income (SSI). This matter is before the Court for disposition based upon plaintiff’s Statement of Errors (Doc. 14), the Commissioner’s response (Doc. 15), and plaintiff’s reply (Doc. 16). I. Procedural Background Plaintiff protectively filed her applications for DIB and SSI in January 2016 (Tr. 25), alleging disability since July 27, 2015, due to fibromyalgia, depression, and chronic back pain (Tr. 118, 133). The applications were denied initially and upon reconsideration. Plaintiff, through counsel, requested and was granted a de novo hearing before administrative law judge (ALJ) Thuy-Anh Nguyen. Plaintiff and a vocational expert (VE) appeared and testified at the ALJ hearing on August 14, 2018. On December 5, 2018, the ALJ issued a decision denying

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. plaintiff’s DIB and SSI applications. The Appeals Council denied plaintiff’s request for review on June 29, 2020, making the ALJ’s decision the final decision of the Commissioner. 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) (DIB), 1382c(a)(3)(A) (SSI). 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), 1382c(a)(3)(B). 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. 2 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). 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 March 31, 2019. 2.[Plaintiff] has not engaged in substantial gainful activity since July 27, 2015, the alleged onset date (20 CFR 404.1571 et seq., and 416.971 et seq.). 3.[Plaintiff] has the following severe impairments: disorders of the lumbar spine, osteopenia, fibromyalgia, affective disorder, anxiety disorder, and attention deficit disorder (ADD) (20 CFR 404.1520(c) and 416.920(c)). 4.[Plaintiff] does not have 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, 404.1526, 416.920(d), 416.925 and 416.926). 5.After careful consideration of the entire record, the [ALJ] finds that [plaintiff] has the residual functional capacity to perform light work, as defined in 20 CFR 404.1567(b) and 416.967(b), except: [plaintiff] can occasionally climb ramps and stairs, but she can never climb ladders, ropes, and scaffolds. She can occasionally balance, stoop, kneel, crouch, and crawl. She can 3 occasionally operate foot pedals with the right lower extremity and can frequently operate foot pedals with the left lower extremity. She must avoid concentrated exposure to extreme cold and vibration, and she must avoid all hazards, including unprotected heights. [Plaintiff] can understand, remember, and carry out simple, routine tasks, and she must not perform work involving high production quotas or a fast pace. [Plaintiff] is limited to a low stress work setting, defined as one having occasional changes in a work setting, with such changes explained in advance, and only occasional decision-making. She can occasionally interact with the public, co-workers, and supervisors. 6.[Plaintiff] is unable to perform any past relevant work (20 CFR 404.1565 and 416.965).2 7.[Plaintiff] was born [in] . . . 1967 and was 47 years old, which is defined as a younger individual age 18-49, on the alleged disability onset date. [Plaintiff] subsequently changed age category to closely approaching advanced age (20 CFR 404.1563 and 416.963). 8.[Plaintiff] has a limited education and is able to communicate in English (20 CFR 404.1564 and 416.964).

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Schrichten v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schrichten-v-commissioner-of-social-security-ohsd-2022.