Williams v. Commissioner of Social Security

District Court, S.D. Ohio·Decided September 30, 2024·No. 2:23-cv-01473·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF OHIO WESTERN DIVISION

STEPHEN. W.1 Case No. 2:23-cv-1473

Plaintiff, v. Bowman, M.J.

COMMISSIONER OF SOCIAL SECURITY,

Defendants.

MEMORANDUM OF OPINION AND ORDER

Plaintiff Stephen W. filed this Social Security appeal in order to challenge the Defendant’s finding that he is not disabled. See 42 U.S.C. § 405(g). The parties have consented to the jurisdiction of the undersigned magistrate judge. See 28 U.S.C. §636(c). Proceeding through counsel, Plaintiff presents three claims of error, all of which the Defendant disputes. As explained below, the Administrative Law Judge (ALJ)’s finding of non-disability is REVERSED and REMANDED, because it is not supported by substantial evidence in the administrative record. I. Summary of Administrative Record Plaintiff applied for disability insurance benefits (DIB) in July 2018, claiming disability beginning on January 8, 2018. (Tr. 156-57). His application was denied initially and upon reconsideration. (Tr. 68-72, 82-72). After a hearing, the ALJ issued an unfavorable decision, dated June 28, 2020, finding that Plaintiff was not under a disability

1 The Committee on Court Administration and Case Management of the Judicial Conference of the United States has recommended that, due to significant privacy concerns in social security cases, federal courts should refer to claimants only by their first names and last initials. See General Order 22-01.

as defined in the Social Security Act. Plaintiff appealed that decision to the United States District Court of South Carolina, which remanded the case to the Commissioner upon her motion. (Tr. 756). In May 2022, the Appeals Council remanded the case to the ALJ. (Tr. 769-70). Following a supplemental hearing, in January 2023, ALJ LaFata found Plaintiff disabled beginning May 4, 2021. (Tr. at 607-25).

The ALJ concluded that, prior to May 4, 2021, Plaintiff retained the residual functional capacity (“RFC”) to perform a reduced range of light work with postural and environmental limitations (Tr. 612). At step four, the ALJ concluded that Plaintiff could perform his past relevant work. (Tr. 622). However, beginning May 4, 2021, Plaintiff was reduced to sedentary work and became disabled. (Tr.621, 625). Plaintiff was born in December 1960 and was 57 years old when he filed his application for benefits, and he was 60 years old, on May 4, 2021, when the ALJ found that he was disabled. (Tr. 625). Plaintiff completed high school and some college level courses. (Tr. 176, 554). He has past relevant work in auto-dealerships as a service

advisor, service manager, and parts and service director. (Tr. 176-77, 206-09, 235-38). Based upon the record and testimony presented at the hearing, the ALJ found that Plaintiff had the following severe impairments: “degenerative disc disease of the lumbar spine and degenerative joint disease/osteoarthrosis of the right hip.” (Tr. 609). The ALJ concluded that none of Plaintiff’s impairments alone or in combination met or medically equaled a listed impairment in 20 C.F.R. Part 404, Subp. P, Appendix 1. Despite these impairments, the ALJ determined that prior to May 4, 2021, the date Plaintiff became disabled, Plaintiff retained the RFC to perform light work subject to the following limitations: occasional climbing ramps/stairs; no climbing ladders/ropes/scaffolds; occasional balancing, stooping, kneeling, crouching and crawling; no work at unprotected heights or concentrated exposure to extreme cold; and, occasional operation of a motor vehicle. He would need a sit/stand option, defined as a brief postural change at or near the work station, no more frequently than up to twice in an hour and lasting for no more than up to 5 minutes each. Time off-task can be accommodated by normal breaks.

(Tr. 612). Based upon her RFC and testimony from the vocational expert, the ALJ concluded that prior to May 4, 2021, the Plaintiff was capable of performing his past relevant work of service manager and parts manager. (Tr. 622). Accordingly, the ALJ determined that Plaintiff is not under disability prior to May 4, 2021, as defined in the Social Security Regulations, and is not entitled to DIB. Id. Beginning May 4, 2021, Plaintiff was reduced to sedentary work and found to be disabled. (Tr. 621, 625).2 The Appeals Council denied Plaintiff’s request for review. Therefore, the ALJ’s decision stands as the Defendant’s final determination. On appeal to this Court, Plaintiff argues that the ALJ erred by: (1) improperly evaluating Plaintiff’s RFC; (2) improperly evaluating the opinion of Dr. Durrence; and (3) failing to properly consider Plaintiff’s subjective complaints. Upon close analysis, I conclude that Plaintiff’s assignments of error are well-taken. I. Analysis

2 Since May 4, 2021, the ALJ determined that Plaintiff has had the residual functional capacity to perform sedentary work as defined in 20 CFR 404.1567(a) with the following limitations:

occasional climbing ramps/stairs; no climbing ladders/ropes/scaffolds; occasional balancing, stooping, kneeling, crouching and crawling; no work at unprotected heights or concentrated exposure to extreme cold; and occasional operation of a motor vehicle. He would need a sit/stand option, defined as a brief postural change at or near the work station, no more frequently than twice in an hour lasting for no more than 5 minutes each. Time off- task can be accommodated by normal breaks.

(Tr. 621). A. Judicial Standard of Review To be eligible for benefits, a claimant must be under a “disability.” See 42 U.S.C. §1382c(a). Narrowed to its statutory meaning, a “disability” includes only physical or mental impairments that are both “medically determinable” and severe enough to prevent the applicant from (1) performing his or her past job and (2) engaging in “substantial

gainful activity” that is available in the regional or national economies. See Bowen v. City of New York, 476 U.S. 467, 469-70 (1986). When a court is asked to review the Commissioner’s denial of benefits, the court’s first inquiry is to determine whether the ALJ’s non-disability finding is supported by substantial evidence. 42 U.S.C. § 405(g). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971) (additional citation and internal quotation omitted). In conducting this review, the court should consider the record as a whole. Hephner v. Mathews, 574 F.2d 359, 362 (6th Cir. 1978). If substantial evidence supports

the ALJ’s denial of benefits, then that finding must be affirmed, even if substantial evidence also exists in the record to support a finding of disability. Felisky v. Bowen, 35 F.3d 1027, 1035 (6th Cir. 1994).

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