Smith v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedSeptember 2, 2025
Docket1:25-cv-00040
StatusUnknown

This text of Smith v. Commissioner of Social Security (Smith 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
Smith v. Commissioner of Social Security, (S.D. Ohio 2025).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

MASON D. S.1 ,

Plaintiff,

v. Civil Action 1:25-cv-40 Judge Susan J. Dlott Magistrate Judge Chelsey M. Vascura COMMISSIONER OF SOCIAL SECURITY,

Defendant.

REPORT AND RECOMMENDATION Plaintiff, Mason D. S., brings this action under 42 U.S.C. § 405(g) for review of a final decision of the Commissioner of Social Security (“Commissioner”) denying his applications for Social Security Period of Disability Benefits, Disability Insurance Benefits (“DIB”) and Supplemental Security Income Benefits (“SSI”). This matter is before the undersigned for a Report and Recommendation (“R&R”) on Plaintiff’s Statement of Errors (ECF No. 9); the Commissioner’s Memorandum in Opposition (ECF No. 12); Plaintiff’s Reply (ECF No. 13); and the administrative record (ECF No. 8). 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.

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. I. BACKGROUND Plaintiff filed his DIB application on February 28, 2022, alleging that he became disabled beginning February 8, 2022. Plaintiff’s DIB application was initially denied. Plaintiff then filed his SSI application on August 17, 2022, and alleged the same disability onset date. Plaintiff’s SSI application was escalated, and on March 20, 2023, both of Plaintiff’s applications were denied

upon reconsideration. An Administrative Law Judge (“ALJ”) subsequently held a telephonic hearing on January 4, 2024, at which Plaintiff, accompanied by a non-attorney representative, appeared and testified. A vocational expert (“VE”) also appeared and testified. On January 31, 2024, the ALJ issued an unfavorable determination (R. at 17–31), which became final on December 4, 2024, when the Appeals Council declined review. (Id. at 1–6.) Plaintiff seeks judicial review of that unfavorable determination. Plaintiff contends that the ALJ reversibly erred: 1) when determining if he met or equaled certain listed impairments; 2) when assessing his subjective symptoms (a.k.a. making a credibility determination); and 3) when evaluating medical opinions and prior administrative findings. (Pl.’s Statement of Errors 3–13, ECF No. 9; Pl.’s Reply 1–9, ECF No. 13). The undersigned finds Plaintiff’s three contentions of

error lack merit. II. THE ALJ’s DECISION The ALJ issued the unfavorable determination on January 31, 2024. He initially determined that Plaintiff met the insured status requirements of the Social Security Act through December 31, 2027. (R. at 19.) At step one of the sequential evaluation process,2 the ALJ found that Plaintiff had not engaged in substantial gainful activity since February 8, 2022, his alleged disability onset date. (Id. at19.) At step two, the ALJ found that Plaintiff had the following severe medically determinable impairments: autism spectrum disorder without accompanying intellectual impairment, attention-deficit/hyperactivity disorder (ADHD); anxiety disorder, major

depressive disorder, mood disorder, and encephalopathy. (Id. at 19–20.) The ALJ also found that Plaintiff had the non-severe medically determinable impairment of foot pain following an injury to his foot. (Id. at 20.) At step three, the ALJ found that Plaintiff did not have an impairment or combination of impairments that met or medically equaled one of the listed impairments described in 20 C.F.R. Part 404, Subpart P, Appendix 1. (Id. at 20.)

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). The ALJ then set forth Plaintiff’s residual functional capacity (“RFC”)3 as follows: After careful consideration of the entire record, the undersigned finds that the claimant has the residual functional capacity to perform a full range of work at all exertional levels but with the following nonexertional limitations: requires work related to simple, routine tasks with no set hourly quotas that does not involve conveyor belts or assembly line duties. He can have no more than occasional interactive contact with coworkers and supervisors. He can have no direct interactive contact with the public. There should be no more than occasional changes in the routine work setting. He needs to avoid hazards such as moving machinery and unprotected heights but does not need to avoid hazards typically found in the workplace such as boxes on the floor or ajar doors. (Id. at 22.) At step four, the ALJ relied on testimony from the VE to determine that Plaintiff had no past relevant work. (Id. at 29.) Relying again on the VE’s testimony at step five, the ALJ determined that considering his age, education, work experience, and RFC, there were jobs that existed in significant numbers in the national economy that Plaintiff could perform. (Id.) Accordingly, the ALJ determined that Plaintiff was not disabled as defined in the Social Security Act during the relevant time frame. (Id. at 30.) III. STANDARD OF REVIEW When reviewing a case under the Social Security Act, the Court “must affirm the Commissioner’s decision if it ‘is supported by substantial evidence and was made pursuant to proper legal standards.’” Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647, 651 (6th Cir. 2009) (quoting Rogers v. Comm’r of Soc. Sec., 486 F.3d 234, 241 (6th Cir. 2007)); see also 42 U.S.C. § 405(g) (“[t]he findings of the Commissioner of Social Security as to any fact, if supported by substantial evidence, shall be conclusive . . ..”). Under this standard, “substantial evidence is defined as ‘more than a scintilla of evidence but less than a preponderance; it is such relevant

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