A woman with neuropathy was correctly denied disability benefits by Social Security.

Record source: CourtListener

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY NORTHERN DIVISION at Covington VICKI L. MANNING, ) ) Plaintiff, ) Civil Action No. 2:25-cv-00082-SCM ) v. ) ) MEMORANDUM OPINION COMMISSIONER OF THE SOCIAL ) AND ORDER SECURITY ADMINSITRATION, ) ) Defendant. *** *** *** *** Plaintiff Vicki L. Manning appeals the Social Security Administration’s denial of her claim for Disability Insurance Benefits (“DIB”). [Dkt. 1; Dkt. 19]. Manning requests that the Court reverse the SSA’s decision and remand to the SSA for further proceedings. [Dkt. 16 at 15]. In support of that request, she contends that the Administrative Law Judge (“ALJ”) assigned to her case made two errors. First, Manning argues the ALJ improperly determined her residual functional capacity by failing to account for the total limiting effects of her impairments. [Id. at 2]. Second, she argues the ALJ erred by finding Manning could return to her past job because the ALJ failed to take into account the ALJ’s finding that Manning had mild mental impairments. [Id. at 11]. The Court disagrees and concludes the ALJ’s decision should be affirmed. Therefore, Manning’s request for relief, [Dkt. 1; Dkt. 16], is DENIED and the Court AFFIRMS the ALJ’s decision. [Dkt. 9 at 19–41]. I. Background Manning alleges that she became disabled on March 31, 2020, due to neuropathy. [Dkt. 9 at 66]. Her date last insured is March 31, 2024. [Id. at 23]. She filed an application for DIB on August 1, 2022, which was denied initially and upon reconsideration. [Id. at 66–72, 74–81]. On May 17, 2024, the ALJ assigned to her case found that she was not disabled under the Social Security Act (“Act”) and thus not entitled to DIB. [Id. at 23]. The ALJ, following the five-step process, noted that Manning was unengaged in substantial gainful activity for the requisite period and had some severe physical impairments. [Id. at 23–24]. But because she still had the residual functional capacity to perform her past relevant work, she was not disabled under the Act. [Id. at 39]. Following the ALJ’s decision, Manning requested review by the Appeals Council. [Id. at 11]. The Appeals Council denied her request. [Id. at 5–7]. Having exhausted her administrative remedies, Manning filed the instant Complaint requesting reversal and remand of the ALJ’s decision. [Dkt. 1]. Manning has filed her Plaintiff’s brief, [Dkt. 16], and the Commissioner has filed a response in opposition, [Dkt. 19]. This matter is now ripe for the Court’s decision. II. Legal Standards A. ALJ Evaluation To be entitled to benefits under the Act, a claimant must be adjudicated “disabled” under the definition from 20 C.F.R. § 404.1505. See 20 C.F.R. § 404.1501. The Act defines a “disability” as “the inability to do any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months.” 20 C.F.R. § 404.1505(a). Whether a claimant meets that definition is initially determined by an ALJ in accordance with “a five-step ‘sequential evaluation process.’” Combs v. Comm’r of Soc. Sec., 459 F.3d 640, 642 (6th Cir. 2006) (en banc) (quoting 20 C.F.R. § 404.1520(a)(4)). It is not always necessary to go through all five steps, though. The point of the five-step process is to determine whether a claimant is or is not disabled. So if a claimant is conclusively determined to be either disabled or not disabled at any one of the five steps, then the process does not need to go any further. 20 C.F.R. § 404.1520(a)(4). First, the ALJ considers whether the claimant is engaged in “substantial gainful activity,” defined as work that “[i]nvolves doing significant and productive physical or mental duties” and “[i]s done (or intended) for pay or profit.” 20 C.F.R. §§ 404.1510; 404.1520(a)(4)(i). If the claimant is engaged in substantial gainful activity, she will be found to be not disabled. Id. § 404.1520(a)(4)(i). If the claimant is not engaged in substantial gainful activity, the ALJ continues to step two. Second, the ALJ determines whether the claimant has a severe impairment that meets the duration requirements. Id. § 404.1520(a)(4)(ii). An impairment is severe when it “significantly limits [the claimant’s] physical or mental ability to do basic work activities.” Id. § 404.1520(c). If a claimant is found not to have a severe impairment, that claimant is not disabled. Id. If the claimant is found to have a severe impairment, the ALJ continues to step three. Third, the ALJ analyzes whether the claimant’s impairment(s) meet or equal one of the impairments listed in Appendix 1 to Subpart P of Part 404. Heston v. Comm’r of Soc. Sec., 245 F.3d 528, 534 (6th Cir. 2001); 20 C.F.R. § 404.1520(a)(4)(iii). If so, then the claimant is disabled and the analysis ends. If not, the ALJ continues to step four. Fourth, the claimant’s “residual functional capacity” and “past relevant work” are determined and considered. 20 C.F.R. § 404.1520(a)(4)(iv). If the claimant is capable of performing her past relevant work in light of her residual functional capacity, she will be found not disabled. Id. If the claimant is not so capable, the ALJ continues to step five. Fifth, the claimant’s residual functional capacity is assessed in combination with her age, education, and work experience to determine if she “can make an adjustment to other work.” Id. § 404.1520(a)(4)(v). If an adjustment can be made, the claimant will be found not disabled. Id. If no adjustment can be made, the claimant will be found disabled. Id. B. Standard of Review A district court reviewing an ALJ’s decision to deny benefits may only consider “whether the ALJ applied the correct legal standards and whether the findings of the ALJ are supported by substantial evidence.” Blakley v. Comm’r of Soc. Sec., 581 F.3d 399, 405–06 (6th Cir. 2009) (citing Key v. Callahan, 109 F.3d 270, 273 (6th Cir. 1997)). An “ALJ’s legal rulings, including his interpretation of relevant laws and regulations,” are reviewed de novo. Linden v. Comm’r of Soc. Sec., 131 F.4th 531, 534 (6th Cir. 2025) (citing Cardew v. Comm’r of Soc. Sec., 896 F.3d 742, 746 (6th Cir. 2018)). Factual assessments are reviewed under the substantial evidence standard. Blakley, 581 F.3d at 405–06. Substantial evidence is “su

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