Smith v. Commissioner of Social Security

District Court, S.D. Ohio·Decided June 22, 2022·No. 3:20-cv-00239·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

AMY S.,1

Plaintiff, Case No. 3:20-cv-0239 v. Magistrate Judge Norah McCann King

COMMISSIONER OF SOCIAL SECURITY,2

Defendant.

OPINION AND ORDER

This is an action for review of the final decision of the Commissioner of Social Security that, as of August 31, 2016, Plaintiff Amy S. was no longer entitled to Disability Insurance Benefits under Title II of the Social Security Act, 42 U.S.C. §§ 401 et seq. This matter is now before the Court, with the consent of the parties, see Joint Consent of the Parties, ECF No. 5, on Plaintiff’s Statement of Errors, ECF No. 11, Defendant’s Memorandum in Opposition, ECF No. 14, Plaintiff’s Reply, ECF No. 15, and the Certified Administrative Record, ECF No. 9. After careful consideration of the entire record, the Court decides this matter pursuant to Rule 78(b) of the Federal Rules of Civil Procedure. For the reasons that follow, the Court grants Plaintiff’s Statement of Errors and reverses the Commissioner’s decision and remands the action for further proceedings.

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 plaintiffs in such cases by only their first names and last initials. See also S.D. Ohio General Order 22-01. 2 Kilolo Kijakazi is the Acting Commissioner of Social Security. See Fed. R. Civ. P. 25(d). 1 I. PROCEDURAL HISTORY Plaintiff was found disabled in November 2008 by reason of bipolar disorder and anxiety. R. 67-75.3 Plaintiff was thereafter notified that benefits would be terminated because a review of her medical records demonstrated that her disabling conditions had improved and were no longer

disabling. R. 92. See also R. 142-43 (notice of termination on reconsideration). Plaintiff requested a hearing before an administrative law judge and, on November 7, 2018, Administrative Law Judge Stuart Adkins (“the ALJ”) held a hearing at which Plaintiff, who was represented by counsel, testified, as did a vocational expert. R. 38-66. In a decision dated January 29, 2019, the ALJ held that Plaintiff’s disability ended on August 31, 2016, and she has not become disabled again since that date. R. 7-32. That decision became the final decision of the Commissioner of Social Security when the Appeals Council denied review on April 23, 2020. R. 1-6. Plaintiff timely filed this appeal pursuant to 42 U.S.C. § 405(g). ECF No. 1. On March 23, 2022, the case was reassigned to the undersigned. ECF No. 17. The matter is ripe for disposition. II. LEGAL STANDARD

A. Standard of Review A claimant’s entitlement to disability benefits must be reviewed periodically to determine, inter alia, whether “there has been any medical improvement” in the disabling impairments. 42 U.S.C. § 423(f)(1)(A); 20 C.F.R. § 404.1594(a). “Medical improvement” is defined as “any decrease in the medical severity” of the claimant’s impairments, and is based on “improvements in the symptoms, signs, and/or laboratory findings associated with” the claimant’s impairments. 20 C.F.R. § 404.1594(b)(1). A finding of medical improvement will

3 The Court will refer to pages in the Certified Administrative Record as “R. ,”using the pagination as it appears in the Certified Administrative Record.

2 result in the termination of benefits if “it is also shown that [the claimant is] currently able to engage in substantial gainful activity.” Id. at § 404.1594(b)(3). That determination may be based on all of the claimant’s current impairments, not just those present at the time of the most recent favorable determination. Id. at § 404.1594(b)(5). Unless it is determined that the claimant

remains disabled, the Commissioner “will use the new symptoms, signs and laboratory findings to make an objective assessment of [the claimant’s] functional capacity to do basic work activities or residual functional capacity and [ ] will consider [the claimant’s] vocational factors.” Id. There is “no presumption of continuing disability,” Kennedy v. Astrue, 247 F. App’x 761, 764 (6th Cir. 2007)(citing Cutlip v. Sec’y of Health & Human Servs., 25 F.3d 284, 287 (6th Cir. 1994)). A court reviewing the Commissioner’s decision will affirm the Commissioner’s conclusion “absent a determination that the ALJ failed to apply the correct legal standard or made fact findings unsupported by substantial evidence in the record.” Kyle v. Comm’r of Soc. Sec., 609 F.3d 847, 854 (6th Cir. 2010). See Cutlip, 25 F.3d at 286. 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 . . . .”). The United States Supreme Court has explained the substantial evidence standard as follows: Under the substantial-evidence standard, a court looks to an existing administrative record and asks whether it contains sufficien[t] evidence to support the agency’s factual determinations. And whatever the meaning of substantial in other contexts, the threshold for such evidentiary sufficiency is not high. Substantial evidence, this Court has said, is more than a mere scintilla. It means – and means only – such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.

Biestek v. Berryhill, 139 S.Ct. 1148, 1154 (2019) (internal citations and quotation marks omitted); see also Pierce v. Underwood, 487 U.S. 552, 565 (1988) (citation and internal 3 quotations omitted). In addition, “‘[w]here substantial evidence supports the [Commissioner’s] determination, it is conclusive, even if substantial evidence also supports the opposite conclusion.’” Emard v. Comm’r of Soc. Sec., 953 F.3d 844, 849 (6th Cir. 2020) (quoting Crum v. Sullivan, 921 F.2d 642, 644 (6th Cir. 1990)); see also Blakley v. Comm’r of Soc. Sec., 581 F.3d

399, 406 (6th Cir. 2009) (“Therefore, if substantial evidence supports the ALJ's decision, this Court defers to that finding ‘even if there is substantial evidence in the record that would have supported an opposite conclusion.’”) (quoting Key v. Callahan, 109 F.3d 270, 273 (6th Cir. 1997)). “Yet, even if supported by substantial evidence, ‘a decision of the Commissioner will not be upheld where the SSA fails to follow its own regulations and where that error prejudices a claimant on the merits or deprives the claimant of a substantial right.’” Rabbers v.

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

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