Thrasher v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedFebruary 19, 2020
Docket1:18-cv-00731
StatusUnknown

This text of Thrasher v. Commissioner of Social Security (Thrasher 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
Thrasher v. Commissioner of Social Security, (S.D. Ohio 2020).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION REGINA THRASHER, OBO Case No. 1:18-cv-731 A.S., Dlott, J. Plaintiff, Litkovitz, M.J.

vs. COMMISSIONER OF REPORT AND SOCIAL SECURITY, RECOMMENDATION Defendant.

Plaintiff Regina Thrasher, on behalf of a minor child, A.S., brings this pro se action pursuant to 42 U.S.C. § 405(g) for judicial review of the final decision of the Commissioner of Social Security (Commissioner) denying plaintiff's application for children’s Supplemental Security Income (SSI). This matter is before the Court on plaintiff's Statement of Errors (Doc. 10), the Commissioner’s response in opposition (Doc. 1 1), and plaintiff's reply (Doc. 15). I. Procedural Background A.S. was born in 2008 and was 10 years old at the time of the administrative law judge (ALJ)’s decision. Plaintiff filed an application for children’s SSI benefits on A.S.’s behalf in November 2014, alleging disability due to attention deficit hyperactivity disorder (ADHD). Plaintiff's application was denied initially and upon reconsideration. Plaintiff requested and was granted a de novo hearing before ALJ Christopher Tinsdale. Plaintiff appeared at the June 14, 2017 ALJ hearing without an attorney or other representative.! On May 14, 2018, the ALJ issued a decision denying plaintiff's SSI application. Plaintiff's request for review by the Appeals

' At the hearing, the ALJ explained to plaintiff her right to be represented by an attorney or non-attorney, who could help her obtain and submit records, explain medical terms, make requests, protect her rights, and present the evidence in a light most favorable to A.S.’s case. (Tr. 137). Plaintiff declined representation and elected to proceed

Council was denied, making the decision of the ALJ the final administrative decision of the Commissioner. II. Analysis A. Legal Framework for Disability Determinations To qualify for SSI, the claimant must file an application and be an “eligible individual” as defined in the Act. 42 U.S.C. § 1382(a); 20 C.F.R. § 416.202. Eligibility is dependent upon disability, income, and other financial resources. /d.; 20 C.F.R. § 416.202. An individual under the age of 18 is considered disabled for purposes of SSI “if that individual has a medically determinable physical or mental impairment, which results in marked and severe functional limitations, and which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.” 42 U.S.C. § 1382c(a)(3)(C)(i). The Social Security regulations set forth a three-step sequential analysis for determining whether a child is disabled for purposes of children’s SSI benefits: 1, Is the child engaged in any substantial gainful activity? If so, benefits are denied. 2. Does the child have a medically severe impairment or combination of impairments? If not, benefits are denied. 3. Does the child’s impairment meet, medically equal, or functionally equal any in the Listing of Impairments, Appendix 1 of 20 C.F.R. Pt. 404, Subpt. P? If so, benefits are granted. 20 C.F.R. § 416.924(a)-(d). If an impairment does not meet a listed impairment, disability may nonetheless be established if the child’s impairment is medically or functionally equivalent to a listed impairment. A child’s impairment is “medically equivalent” to a listed impairment if it is “at

with the hearing. (Id.).

least equal in severity and duration to the criteria” of a listed impairment. 20 C.F.R. § 416.926. In determining whether a child’s impairment(s) functionally equals the listings, the adjudicator must assess the child’s functioning in six domains: 1. Acquiring and using information; 2. Attending and completing tasks; 3. Interacting and relating with others; 4. Moving about and manipulating objects; 5. Caring for yourself; and 6. Health and physical well-being. 20 C.F.R. § 416.926a(b)(1)(i)-(vi). To functionally equal an impairment in the listings, an impairment must result in “marked” limitations in two domains of functioning or an “extreme” limitation in one domain. 20 C.F.R. § 416.926a(d). The relevant factors that will be considered in making this evaluation are (1) how well the child initiates and sustains activities, how much extra help he needs, and the effects of structured or supportive settings; (2) how the child functions in school; and (3) the effects of the child’s medications or other treatment. 20 C.F.R. § 416.926a(a)(1)-(3). An individual has a “marked” limitation when the impairment “interferes seriously with [the] ability to independently initiate, sustain, or complete activities.” 20 C.F.R. § 416.926a(e)(2)(1). A “marked” limitation is one that is “more than moderate” but “less than extreme.” /d. An “extreme” limitation exists when the impairment “interferes very seriously with [the] ability to independently initiate, sustain, or complete activities.” 20 C.F.R. §

416.926a(e)(3)(i). Day-to-day functioning may be “very seriously limited” when only one activity is limited by the impairment or when several activities are limited by the impairment’s cumulative effects. Jd. If the child’s impairment meets, medically equals, or functionally equals an impairment in the listings, and if the impairment satisfies the Act’s duration requirement, then the child is considered disabled. 20 C.F.R. § 416.924(d)(1). If both requirements are not satisfied, then the child is not considered disabled. 20 C.F.R. § 416.924(d)(2). B. The ALJ’s findings The ALJ applied the sequential evaluation process and made the following findings of fact and conclusions of law: 1. [A.S.] was born [in] . . . 2008. Therefore, he was a school-age child on November 19, 2014, the date the application was filed, and is currently a school- age child (20 CFR 416.926a(g)(2)). 2. [A.S.] has not engaged in substantial gainful activity since November 19, 2014, the application date (20 CFR 416.924(b) and 416.971 ef seq.). 3. [A.S.] has the following severe impairment: attention deficit hyperactivity disorder (ADHD) (20 CFR 416.924(c)). 4. [A.S.] does not have an impairment or combination of impairments that meets or medically equals the severity of an impairment listed in 20 CFR Part 404

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Thrasher v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/thrasher-v-commissioner-of-social-security-ohsd-2020.