Trista L. v. Commissioner of Social Security

CourtDistrict Court, S.D. Ohio
DecidedApril 27, 2026
Docket2:25-cv-01184
StatusUnknown

This text of Trista L. v. Commissioner of Social Security (Trista L. 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.

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Trista L. v. Commissioner of Social Security, (S.D. Ohio 2026).

Opinion

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

TRISTA L.,

Plaintiff, v. Civil Action 2:25-cv-01184 Magistrate Judge Kimberly A. Jolson

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

OPINION AND ORDER Plaintiff, Trista L., 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 reasons set forth below, the Court OVERRULES Plaintiff’s Statement of Errors (Doc. 9) and AFFIRMS the Commissioner’s decision. I. BACKGROUND Plaintiff filed her applications for DIB and SSI on December 5, 2023, alleging disability beginning June 2, 2023, due to rheumatoid arthritis, fibromyalgia, L5-F1 disc ruptures, degenerative disc disease in lower back, cartilage of left hip torn, torn ligaments, pinched nerve and bruised bone in knee, inability to walk or stand long periods, chronic fatigue and insomnia, and memory loss and concentration issues. (R. at 230–38, 300). After her applications were denied initially and on reconsideration, Administrative Law Judge Matthew Winfrey (the “ALJ”) held a telephone hearing on January 28, 2025. (R. at 55–80). The ALJ denied benefits in a written decision on February 20, 2025. (R. at 31–54). The Appeals Council denied Plaintiff’s request for review, making the ALJ’s decision the final decision of the Commissioner. (R. at 1–6). Plaintiff filed the instant case seeking a review of the Commissioner’s decision on October 10, 2025 (Doc. 1), and the Commissioner filed the administrative record on December 5, 2025. (Doc. 8). The matter has been briefed and is ripe for consideration. (Docs. 9, 11).

The ALJ found that Plaintiff meets the insured status requirements through September 30, 2027. (R. at 36). The ALJ found that Plaintiff has not engaged in substantial gainful activity since June 2, 2023, her alleged onset date of disability. (Id.). The ALJ determined that Plaintiff suffered from the severe impairments of rheumatoid arthritis; headaches; sciatica; failed lumbar back syndrome; status post lumbar discectomy; right foot joint degeneration; left knee arthralgia; and left hip bursitis. (R. at 37). The ALJ, however, found that none of Plaintiff’s impairments, either singly or in combination, meets or medically equals a listed impairment. (R. at 39). The ALJ summarized Plaintiff’s statements to the agency and the testimony from the administrative hearing, as well as Plaintiff’s medical records. (R. at 39–44). As to Plaintiff’s

residual functional capacity (“RFC”), the ALJ opined: After careful consideration of the entire record [the ALJ] finds that [Plaintiff] has the residual functional capacity to perform sedentary work as defined in 20 CFR 404.1567(a) and 416.967(a) except occasionally climb ramps and stairs; occasionally stoop, kneel, crouch, crawl; no balancing as defined by the Selected Characteristics of Occupations; no climbing of ladders, ropes, scaffolds; no exposure to hazards as defined in the Dictionary of Occupational Titles; and will be off task 5% of the time during the workday due to pain and other symptoms.

(R. at 41).

Upon “careful consideration of the evidence,” the ALJ found that Plaintiff’s “statements concerning the intensity, persistence and limiting effects of [her] symptoms are not entirely consistent with the medical evidence and other evidence in the record.” (R. at 42). Relying on the vocational expert (“VE”)’s testimony, the ALJ concluded that Plaintiff is unable to perform her past relevant work as an auto parts counter clerk and assistant manager for auto parts store. (R. at 46). Further relying on the VE testimony, the ALJ determined that considering her age, education, work experience, and RFC, there are jobs that exist in significant numbers in the national economy that Plaintiff can perform, such as a parts inspector or charge

account clerk. (R. at 46–47). Consequently, the ALJ concluded that Plaintiff has not been disabled within the meaning of the Social Security Act, since June 2, 2023. (R. at 47). II. STANDARD OF REVIEW The Court’s review “is limited to determining whether the Commissioner’s decision is supported by substantial evidence and was made pursuant to proper legal standards.” Winn v. Comm’r of Soc. Sec., 615 F. App’x 315, 320 (6th Cir. 2015); see also 42 U.S.C. § 405(g). “[S]ubstantial evidence is defined as ‘more than a scintilla of evidence but less than a preponderance; it is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’” Rogers v. Comm’r of Soc. Sec., 486 F.3d 234, 241 (6th Cir. 2007) (quoting

Cutlip v. Sec’y of HHS, 25 F.3d 284, 286 (6th Cir. 1994)). “After the Appeals Council reviews the ALJ’s decision, the determination of the council becomes the final decision of the Secretary and is subject to review by this Court.” Olive v. Comm’r of Soc. Sec., No. 3:06 CV 1597, 2007 WL 5403416, at *2 (N.D. Ohio Sept. 19, 2007) (citing Abbott v. Sullivan, 905 F.2d 918, 922 (6th Cir. 1990); Mullen v. Bowen, 800 F.2d 535, 538 (6th Cir. 1986) (en banc)). If the Commissioner’s decision is supported by substantial evidence, it must be affirmed, “even if a reviewing court would decide the matter differently.” Id. (citing 42 U.S.C. § 405(g); Kinsella v. Schweiker, 708 F.2d 1058, 1059–60 (6th Cir. 1983)). III. DISCUSSION

In her Statement of Errors, Plaintiff contends that the ALJ did not sufficiently explain why he included a limitation of 5% time off task in Plaintiff’s RFC. (Doc. 9 at 6–10). Plaintiff also claims that the ALJ failed to follow the requirements of SSR 24-3p when soliciting the VE’s testimony about job numbers and, as a result, did not carry the Commissioner’s burden at step five. (Id. at 10–13). The Court disagrees on both counts. A. The ALJ’s 5% Off Task Time RFC Finding A plaintiff’s RFC “is defined as the most [she] can still do despite the physical and mental limitations resulting from [her] impairments.” Poe v. Comm’r of Soc. Sec., 342 F. App’x 149, 155 (6th Cir. 2009); see also 20 C.F.R. § 404.1545(a)(1). “The responsibility for determining a claimant’s residual functional capacity rests with the ALJ, not a physician.” Poe, 342 F. App’x at 157; see 20 C.F.R. § 404.1546(c); see also Webb v. Comm’r of Soc. Sec., 368 F.3d 629, 633 (6th

Cir. 2004) (“[T]he ALJ is charged with the responsibility of evaluating the medical evidence and the claimant’s testimony to form an ‘assessment of his [RFC].’”).

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