West v. Commissioner of Social Security

CourtDistrict Court, N.D. Ohio
DecidedFebruary 3, 2025
Docket3:24-cv-01209
StatusUnknown

This text of West v. Commissioner of Social Security (West v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, N.D. Ohio primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
West v. Commissioner of Social Security, (N.D. Ohio 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

BRANDY D. WEST, ) CASE NO. 3:24-CV-01209-JRK ) Plaintiff, ) JUDGE JAMES R. KNEPP, II ) UNITED STATES DISTRICT JUDGE v. ) ) MAGISTRATE JUDGE COMMISSIONER OF SOCIAL SECURITY, ) CARMEN E. HENDERSON ) Defendant, ) REPORT & RECOMMENDATION )

I. Introduction Plaintiff, Brandy West (“West” or “Claimant”), seeks judicial review of the final decision of the Commissioner of Social Security denying her applications for Supplemental Security Income (“SSI”) and Disability Insurance Benefits (“DIB”). This matter is before me pursuant to 42 U.S.C. §§ 405(g), 1383(c)(3), and Local Rule 72.2(b). For the reasons set forth below, it is RECOMMENDED that the Court OVERRULE Claimant’s Statement of Errors and AFFIRM the Commissioner’s decision. II. Procedural History On June 17, 2022, West filed applications for DIB and SSI, alleging a disability onset date of June 1, 2022. (ECF No. 7, PageID #: 301, 304, 306). The applications were denied initially and upon reconsideration, and West requested a hearing before an administrative law judge (“ALJ”). (ECF No. 7, PageID #: 190). On July 25, 2023, an ALJ held a hearing, during which Claimant, represented by counsel, and an impartial vocational expert testified. (ECF No. 7, PageID #: 61, 88, 101). On, October 3, 2023 the ALJ issued a written decision finding West was not disabled. (ECF No. 7, PageID #: 76). The ALJ’s decision became final on May 17, 2024, when the Appeals Council declined further review. (ECF No. 7, PageID #: 28–30). On July 17, 2024, West filed her Complaint to challenge the Commissioner’s final decision. (ECF No. 1). The parties have completed briefing in this case. (ECF Nos. 8, 10). West

asserts the following assignment of error: “the ALJ violated 20 C.F.R. § 404.1520c during the evaluation of the consultative examiner’s opinions.” (ECF No. 8 at 8). Specifically, West argues that the ALJ failed to adequately address the supportability and consistency of the opinion belonging to Ms. Wheatley, a Certified Nurse Practitioner hired by the Social Security Administration to examine West, and, thus, that she failed to meet the requirements for evaluating medical opinions and prior administrative medical findings under 20 C.F.R. § 404.1520c. (ECF No. 8 at 8–10). West asserts that because of this failure, the ALJ’s decision is not supported by substantial evidence. (ECF No. 8 at 13). III. Background A. Relevant Hearing Testimony

At her July 25, 2023 hearing, West testified that she suffered from seizures and last had a seizure in June of 2023, while she was at work. (ECF No. 7, PageID #: 96–97). She testified that she previously suffered from seizures everyday but explained that her medication had helped, and her seizures occurred less often since she became “used to the medication.” (ECF No. 7, PageID #: 96–97). The ALJ asked West’s attorney, Mr. Niper, if there was an abnormal EEG in the record, to which he replied that there was not. (ECF No. 7, PageID #: 96). West additionally testified that she was having difficulty seeing out of her left eye but said she had not been to an ophthalmologist and did not know the source of her poor vision. (ECF No. 7, PageID #: 97–98). She testified that she suspected her left eye problems may have arisen as a side effect of her medication or because of her frequent falling/seizure episodes. (ECF No. 7, PageID #: 97–98). West also explained that when she worked as a stocker or forklift operator, she would at times lift objects that weighed over fifty pounds. (ECF No. 7, PageID #: 95). B. Relevant Medical Evidence

The ALJ summarized West’s health records and symptoms: The claimant’s first seizure was reportedly in January 2022, though she did not go to the emergency department at that time (4F/1). The claimant was not on any medications until March 11, 2022, when the claimant started taking Keppra, 500 milligrams a day, twice a day (1F/7). The claimant also alleged having a loss of sense of smell and taste, which have made it a challenge for her to meet her caloric needs (1F/7). With respect to her symptoms, the claimant reported that she was unable to work due to her seizure disorder. The claimant alleges having daily headaches and seizure episodes several times a week (4F/1). The claimant is purportedly paranoid to go out in public due to seizures and she no longer drives (4F/1). The claimant needs someone at home while she showers and bathes in case[] of seizures and injury (4F/1). The claimant also cannot be around flickering lights (4F/1). . . . On March 15, 2022, the claimant had 2-3 generalized tonic- clonic seizures in the workplace. Rather than rely upon her primary care provider, the claimant followed up with Supriya Mahajan, M.D., Steven Benedict, M.D., and Nicole Danner, D.O., who are all neurologists (1F, 6F, 8F, and 10F). The claimant has epilepsy (1F and 6F). Her seizures have been managed with medications including Keppra, Topamax, Vimpat (lacosamide), and (6F) [sic]. The positive objective clinical and diagnostic findings since the alleged onset date detailed below do not support more restrictive functional limitations than those assessed herein. At her initial evaluation, Dr. Mahajan observed the claimant was oriented person, place, and time, with intact recent and remote memory, normal attention span and concentration, and normal language testing for comprehension, repetition, expression, and naming (1F/9). The claimant’s general fund of knowledge was intact (1F/9, dated March 17, 2022). The claimant’s motor examination was normal and she had normal muscle bulk and tone in both upper extremities and lower extremities (1F/9). The claimant had full (5/5) strength in the distal and proximal muscles in both the upper extremities and lower extremities, and there were no fasciculations, tremors, or other abnormal movements (1F/9). The claimant exhibited normal coordination and had intact finger-nose-finger testing in both upper extremities, with no evidence of dysmetria, dysdiadochokinesia (1F/9). The claimant had intact heel-to-shin movements in both lower extremities (1F/9). The claimant however demonstrated mild sensory ataxia (1F/9). A magnetic resonance imaging (MRI) of the claimant’s brain was normal (1F/11 and 10F/26-27, dated April 8, 2022). The claimant also had a normal electroencephalography (EEG) (1F/11; 5F/11; and 10F/25-26, dated April 8, 2022). [Dr. Mahajan] increased Keppra dosage to 1000 milligrams, twice a day and added Topamax for migraine prophylaxis (1F/14). She had three breakthrough events (1F/14). Dr. Mahajan noted in May 2022, the claimant had no difficulty following single step commands, though she was mildly repetitive, tangential, and inattentive (10F/15). She was friendly and socially appropriate (10F/15). There were no involuntary movements observed and the claimant was able to touch her nose smoothly without dysmetria. The claimant’s rapid alternating ha[n]d movements and heel to shin movements were normal (10F/15). Her gait was stable (10F/15). The claimant has[] a severe seizure disorder, but the claimant’s treatment seeking behavior and the level of treatment provided are not consistent with a disabling seizure disorder. The record indicates the claimant’s symptoms have been conservatively managed with medication therapy. In June 2022, Dr. Mahajan noted had they had been progressively up-titrating the claimant to 2000 milligrams of Keppra a day in addition to Topamax 50 milligrams twice a day, though the claimant reported having passing out events (10F/ 217).

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West v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/west-v-commissioner-of-social-security-ohnd-2025.