Lawson v. Commissioner of Social Security
3:24-cv-00310
S.D. OhioMay 22, 2025Background:
- Plaintiff Christopher A. L. applied for Disability Insurance Benefits under 42 U.S.C. § 405(g), claiming disability onset as of April 1, 2023, due to heart failure, hypertension, and obesity.
- The Social Security Administration (SSA) denied his claim initially and on reconsideration.
- An ALJ held a telephonic hearing on July 17, 2024, and issued an unfavorable decision, finding the Plaintiff not disabled and capable of performing his past relevant work as a security guard.
- The ALJ relied on testimony from a vocational expert (VE) who stated that plaintiff’s residual functional capacity (RFC) allowed him to perform light work, including his prior position.
- After the Appeals Council declined review, Plaintiff sought judicial review, primarily arguing that the ALJ erred in determining he could perform his past work.
- The Magistrate Judge recommends affirming the ALJ’s decision, finding it supported by substantial evidence and compliant with applicable legal standards.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ erred in finding Plaintiff can do past work | ALJ wrongly found Plaintiff capable of security guard position | ALJ properly relied on VE testimony & RFC finding | ALJ did not err; decision supported by substantial evidence |
| Accuracy of RFC determination by ALJ | RFC should include sedentary work only & unscheduled breaks | State agency reviewers supported light work; no medical need for breaks | ALJ’s RFC supported by record; no error |
| Consistency of VE testimony with DOT | VE testimony conflicted with DOT due to environment restrictions | VE said his testimony matched DOT; any conflict should be raised by counsel | No error; Plaintiff’s counsel failed to challenge VE at hearing |
| Requirement to include unscheduled breaks in RFC | Plaintiff’s testimony on breaks means limitation should be in RFC | No medical evidence for unscheduled breaks; ALJ not required to include | No need to include break requirement; ALJ’s RFC affirmed |
Key Cases Cited
- DeLong v. Comm’r of Soc. Sec., 748 F.3d 723 (6th Cir. 2014) (standard for judicial review of SSA decisions is substantial evidence)
- Colvin v. Barnhart, 475 F.3d 727 (6th Cir. 2007) (explains five-step sequential disability framework)
- Henley v. Astrue, 573 F.3d 263 (6th Cir. 2009) (application of sequential analysis in disability claims)
- Foster v. Halter, 279 F.3d 348 (6th Cir. 2001) (ALJ's role in resolving sequential disability questions)
- Golden Living Ctr.-Frankfort v. Sec’y Of Health And Hum. Servs., 656 F.3d 421 (6th Cir. 2011) (review of SSA decisions must consider the whole record)
- Her v. Comm’r of Soc. Sec., 203 F.3d 388 (6th Cir. 1999) (affirmance required if substantial evidence supports ALJ)