Stiles v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedMarch 12, 2025
Docket2:24-cv-03878
StatusUnknown

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

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF OHIO EASTERN DIVISION

AUTUMN S.,

Plaintiff, v. Civil Action 2:24−cv−03878 Judge Sarah D. Morrison Magistrate Judge Kimberly A. Jolson

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

REPORT AND RECOMMENDATION Plaintiff, Autumn S. brings this action under 42 U.S.C. § 405(g) seeking review of a final decision of the Commissioner of Social Security (“Commissioner”) denying her applications for Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”). For the following reasons, the Undersigned RECOMMENDS that the Court SUSTAIN Plaintiff’s Statement of Errors (Doc. 10), REVERSE the Commissioner of Social Security’s non-disability finding, and REMAND this case to the Commissioner and the ALJ under Sentence Four of § 405(g). I. BACKGROUND Plaintiff filed her applications for DIB and SSI in August 2021, alleging disability beginning July 31, 2020, due to aggravated depression, severe anxiety, agoraphobia, and seizures. (R. at 566−72, 573−80, 598). After her applications were denied initially and on reconsideration, Administrative Law Judge Noceeba Southern (the “ALJ”) heard the case on April 5, 2023. (R. at 117−35). Ultimately, the ALJ denied Plaintiff’s applications in a written decision on August 22, 2023. (R. at 19−41). The Appeals Council denied Plaintiff’s request for review, making the ALJ’s ruling the Commissioner’s final decision. (R. at 1–7). Plaintiff filed the instant case seeking a review of the Commissioner’s decision on August 23, 2024. (Doc. 1). As required, the Commissioner filed the administrative record, Plaintiff filed a statement of errors, and the Commissioner filed a response. (Docs. 7, 10, 12). No reply was filed, and the matter is ripe for consideration.

A. Relevant Hearing Testimony and Statements to the Agency When discussing the “paragraph B” criteria, the ALJ summarized Plaintiff’s statements to the agency as follows: [Plaintiff] reported when she gets upset, she is not able to remember things well, is easily distracted, and sometimes is not able to understand what others are explaining (Exhibit B3E). During a psychological consultative examination, [Plaintiff]’s mental functioning was found to be completely intact with the exception of several instances of poor effort in assessment of her working memory. Her immediate, recent, and remote memory appeared intact. She exhibited a clear lack of effort at tasks appearing to give up easily. She reported in past jobs she understood directions (Exhibit B22F). During a neuropsychological evaluation, [Plaintiff]’s memory performance varied by task. [Plaintiff]’s neuropsychological profile reflected deficits across selected measures of attention and memory (Exhibit B28F/4). [Plaintiff] reported difficulty going out in public without having a panic attack. She noted that she texts with others and occasionally goes to get coffee or sits at home with others and chats. [Plaintiff] reported that she hates her sisters, is afraid of people, and she really does not like people (Exhibit B3E). During the consultative examination, [Plaintiff] denied talking to neighbors and friends and has trouble with authority figures. She did not report relationship issues with supervisors or coworkers in the past but noted having been arrested for charges including assault, domestic violence, domestic menacing, and complicity to theft (Exhibit B22F). [Plaintiff] generally presents as calm, pleasant, and cooperative (Exhibits B23F/71, 46; B25F/61; B30F/10; B33F/27, 60). Although, at times, she is irritable and agitated (Exhibits B23F/177; B24F/6; B25F/101; B36F/99). [Plaintiff] reported that she follows directions “pretty well”, but she must go over them many times. She indicated that she does not follow spoken instructions well without having them repeated more than once. [Plaintiff] reported being unable to pay attention for long noting that she will “zone out” (Exhibit B3E). The consultative examiner noted that [Plaintiff] appeared attentive, and her concentration seemed intact. She was able to attend throughout the examination and did not appear to have difficulty with focus (Exhibit B22F). Treatment notes reflect [Plaintiff]’s report that cannabis helps her with concentration (Exhibit B33F/49). During the consultative examination, [Plaintiff] reported her mood as depressed and anxious most of the time. She stated that she gets upset very and overwhelmed very easily and does not know how to calm herself down. While she reported feeling anxious, she did not exhibit overt behavioral manifestations of anxiety. Her speech was clear and understandable, and she did not have any problems expressing herself. Her thought processes appeared generally clear, linear, organized, and goal directed. The consultative examiner noted that [Plaintiff] did not appear to have any deficits in her performance of activities of daily living secondary to her mental health (Exhibit B22F). Mental health treatment notes indicate that through medication management and therapy, [Plaintiff]’s ability to handle stressors has improved (Exhibits B23F/60, 122, 132, 137; B36F/15, 37; B37F/24, 84). [Plaintiff] typically presents as neatly groomed in appropriate attire (Exhibits B23F/68, 77, 87; B24F/6; B28F/3). She testified that she has no issues the ability to care for her seven-year-old daughter.

(R. at 27–28).

The ALJ summarized Plaintiff’s testimony from the administrative hearing as follows: [Plaintiff] testified to, or elsewhere indicated an inability to work primarily due to mental health problems. She testified that she is terrified of people and has panic attacks when she goes out in public. She stated that she gets mad at everyone, and she does not leave the house unless it is completely necessary. She stated that she can only be in a grocery store for 15 minutes before panic sets in. [Plaintiff] testified that she does not trust anyone even her friends, and she feels uncomfortable around everyone. [Plaintiff] stated that she experiences memory problems and forgets everything. She said she has dreams she thinks are real and experiences real things she thinks are dreams. She testified that she is not good at keeping things in order and forgets where she puts things noting that she leaves herself reminder notes. She testified that she either sleeps too much or not enough. [Plaintiff] stated that she has panic attacks triggered by different things causing her to cry, feel dizzy and confused, short of breath, and shaky, which can last 10 minutes up to an hour or more depending on the situation and the trigger.

(R. at 29).

B. Relevant Medical Evidence The ALJ summarized Plaintiff’s medical records and symptoms related to her mental health issues as follows: Since the prior ALJ decision, the record documents ongoing mental health treatment with good response to medication and therapy (Exhibits B23F; B36F; B37F). Treatment notes document that in 2020, [Plaintiff] made progress setting boundaries with family member and her partner, reduced the amount of conflict with others, and was better able to manage stress (Exhibit B23F/60). While [Plaintiff] reported feeling overwhelmed, stressed, and anxious in relation to situational stressors such as housing issues, concern over her father’s health, family deaths, and divorce, it is often noted that [Plaintiff] has been doing well overall and handling things better than in the past (Exhibit B23F/122, 132, 137). [Plaintiff] did seek evaluation for increased forgetfulness and memory issues following motor vehicle accidents, as well as complaints of spells of altered consciousness. In July 2021, [Plaintiff] presented to the emergency room with symptoms consistent with concussion. A head CT showed no intracranial abnormality. (B25F/102, 116).

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Stiles v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/stiles-v-commissioner-of-social-security-ohsd-2025.