Wisenbaugh v. Commissioner of Social Security

CourtDistrict Court, W.D. Michigan
DecidedDecember 11, 2024
Docket1:24-cv-00277
StatusUnknown

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

Bluebook
Wisenbaugh v. Commissioner of Social Security, (W.D. Mich. 2024).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF MICHIGAN SOUTHERN DIVISION

DANIEL W.,

Plaintiff, v. Hon. Sally J. Berens

COMMISSIONER OF Case No. 1:24-cv-277 SOCIAL SECURITY,

Defendant. _____________________________________/

OPINION This is an action pursuant to Section 205(g) of the Social Security Act, 42 U.S.C. § 405(g), to review a final decision of the Commissioner of Social Security denying Plaintiff’s claim for Disability Insurance Benefits (DIB) and Supplemental Security Income (SSI) under Titles II and XVI of the Social Security Act. The parties have agreed to proceed in this Court for all further proceedings, including an order of final judgment. Section 405(g) limits the Court to a review of the administrative record and provides that if the Commissioner’s decision is supported by substantial evidence and in accordance with the law it shall be conclusive. The Commissioner has found that Plaintiff is not disabled within the meaning of the Act. Plaintiff seeks judicial review of this decision. For the following reasons, the Court will reverse the Commissioner’s decision and remand the matter for further factual findings pursuant to sentence four of 42 U.S.C. § 405(g). Standard of Review The Court’s jurisdiction is confined to a review of the Commissioner’s decision and of the record made in the administrative hearing process. See Willbanks v. Sec’y of Health and Human Servs., 847 F.2d 301, 303 (6th Cir. 1988). The scope of judicial review in a social security case is limited to determining whether the Commissioner applied the proper legal standards and whether there exists in the record substantial evidence supporting the decision. See Brainard v. Sec’y of Health and Human Servs., 889 F.2d 679, 681 (6th Cir. 1989). The Court may not conduct a de novo review of the case, resolve evidentiary conflicts, or decide questions of credibility. See Garner v. Heckler, 745 F.2d 383, 387 (6th Cir. 1984). Fact finding is the

Commissioner’s province, and those findings are conclusive provided substantial evidence supports them. See 42 U.S.C. § 405(g). Substantial evidence is more than a scintilla but less than a preponderance. See Cohen v. Sec’y of Dept. of Health & Human Servs., 964 F.2d 524, 528 (6th Cir. 1992). It is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. See Richardson v. Perales, 402 U.S. 389, 401 (1971); Bogle v. Sullivan, 998 F.2d 342, 347 (6th Cir. 1993). In applying this standard, a court must consider the evidence as a whole, while accounting for any evidence that fairly detracts from its weight. See Richardson v. Sec’y of Health and Human Servs., 735 F.2d 962, 963 (6th Cir. 1984). The substantial evidence standard contemplates a zone

within which the decision maker can properly rule either way without judicial interference. See Mullen v. Bowen, 800 F.2d 535, 545 (6th Cir. 1986). This standard affords the administrative decision maker considerable latitude and precludes reversal simply because the evidence would have supported a contrary decision. See Bogle, 998 F.2d at 347; Mullen, 800 F.2d at 545. Procedural Posture Plaintiff filed a prior application for DIB on February 6, 2018, alleging a disability onset date of July 17, 2017. Following a hearing before an Administrative Law Judge (ALJ), his application was denied in a written decision issued on January 28, 2020. (PageID.94-105.) The Appeals Council denied Plaintiff’s request for review on August 17, 2020. (PageID.109-11.) Plaintiff did not seek judicial review of the decision. On January 11, 2022, Plaintiff protectively filed applications for DIB and SSI, alleging that he became disabled as of July 17, 2017, due to blindness or low vision, a shoulder labral tear injury that was poorly repaired, post-traumatic stress disorder, anxiety, borderline personality disorder, impaired hearing, disc degeneration and bulging disc in the neck and left shoulder, and right leg numbness. (PageID.115, 128, 265–78, 339–45.) He later amended his alleged onset date

to January 14, 2021. (PageID.41.) Plaintiff was age 44 both at the time of his amended alleged onset date and when he filed his applications. (PageID.115.) He had completed high school and one year of college, and his past work included Assembly Press Operator, Racker, Injection Molding Machine Off-Bearer, Plating Equipment Operator, Grinder, Set-up Drill Operator, and General Laborer. (PageID.103.) Plaintiff’s applications were denied initially and upon reconsideration, and he requested a hearing before an ALJ. ALJ Paul W. Jones conducted a hearing on January 25, 2023, and received testimony from Plaintiff and James Breen, an impartial vocational expert (VE). (PageID.60–89.) On March 1, 2023, the ALJ issued a written decision finding that Plaintiff was not disabled from his

amended alleged onset date through the date of the decision. (PageID.41–53.) The Appeals Council denied Plaintiff’s request for review on January 17, 2024 (PageID.22–24), making ALJ Jones’s March 1, 2023 decision the Commissioner’s final decision. See Cook v. Comm’r of Soc. Sec., 480 F.3d 432, 434 (6th Cir. 2007). Plaintiff initiated this action for judicial review on March 1, 2024. Analysis of the ALJ’s Opinion The social security regulations articulate a five-step sequential process for evaluating disability. See 20 C.F.R. §§ 404.1520(a-f), 416.920(a-f).1 If the Commissioner can make a dispositive finding at any point in the review, no further finding is required. See 20 C.F.R. §§ 404.1520(a), 416.920(a). The regulations also provide that, if a claimant suffers from a

nonexertional impairment as well as an exertional impairment, both are considered in determining his or her residual functional capacity (RFC). See 20 C.F.R. §§ 404.1545, 416.945. The burden of establishing the right to benefits rests squarely on Plaintiff’s shoulders, and he can satisfy his burden by demonstrating that his impairments are so severe that he is unable to perform his previous work and cannot, considering his age, education, and work experience, perform any other substantial gainful employment existing in significant numbers in the national economy. See 42 U.S.C. § 423

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Bowen v. Yuckert
482 U.S. 137 (Supreme Court, 1987)
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Ronnie Keeton v. Comm'r of Social Security
583 F. App'x 515 (Sixth Circuit, 2014)
Brooke Taskila v. Comm'r of Social Security
819 F.3d 902 (Sixth Circuit, 2016)
Gross v. Commissioner of Social Security
247 F. Supp. 3d 824 (E.D. Michigan, 2017)

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Wisenbaugh v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/wisenbaugh-v-commissioner-of-social-security-miwd-2024.