Court Affirms Denial of Disability Benefits in Parise v. Commissioner of Social Security
Summary
Plaintiff Sandra L. Parise filed this federal court action seeking review of the Commissioner of Social Security's denial of her applications for disability insurance benefits and supplemental security income. The case arose after an administrative law judge denied her claims on May 14, 2024, and the Appeals Council denied her request for review on February 11, 2025. On March 27, 2026, the U.S. District Court for the Northern District of Ohio affirmed the Commissioner's denial, finding substantial evidence in the record supported the administrative decision. The court's ruling represents the final judicial determination of Ms. Parise's disability benefits claims under the applicable administrative review framework.
“For the reasons that follow, the Court AFFIRMS the Commissioner's denial of Plaintiff's applications for disability insurance benefits and supplemental security income benefits.”
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What changed
The court affirmed the Commissioner's denial of disability insurance benefits and supplemental security income benefits, finding the administrative law judge's decision was supported by substantial evidence in the record. The case involved Ms. Parise's claim of disability with an alleged onset date of November 17, 2018, which was denied initially on July 6, 2023, and on reconsideration on October 5, 2023. After a hearing on April 9, 2024, the ALJ issued a written decision finding Plaintiff not disabled on May 14, 2024.
Affected parties—individuals seeking Social Security disability benefits—should note that federal courts review disability denials for substantial evidence rather than reweighing the evidence de novo. The procedural pathway involves initial denial, reconsideration, ALJ hearing, Appeals Council review, and finally federal court review under 42 U.S.C. § 405(g). This ruling underscores that claimants must present sufficient medical evidence to establish disability during the required period.
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March 27, 2026 Get Citation Alerts Download PDF Add Note
Sandra Leigh Parise v. Commissioner of Social Security
District Court, N.D. Ohio
- Citations: None known
- Docket Number: 4:25-cv-00613
Precedential Status: Unknown Status
Trial Court Document
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF OHIO
EASTERN DIVISION
SANDRA LEIGH PARISE, ) Case No. 4:25-cv-00613
)
Plaintiff, ) Judge J. Philip Calabrese
)
v. ) Magistrate Judge
) Jonathan D. Greenberg
COMMISSIONER OF SOCIAL )
SECURITY, )
)
Defendant. )
)
OPINION AND ORDER
Plaintiff Sandra L. Parise applied for disability insurance benefits and
supplemental security income benefits, and the Commissioner of Social Security
denied her application. After a hearing, an administrative law judge also denied her
application. Plaintiff appealed, but the Appeals Council denied her request for
review. Then Plaintiff filed this action, seeking review in federal court. For the
reasons that follow, the Court AFFIRMS the Commissioner’s denial of Plaintiff’s
applications for disability insurance benefits and supplemental security income
benefits.
FACTUAL AND PROCEDURAL BACKGROUND
Plaintiff first applied for disability insurance benefits and supplemental
security benefits on October 6, 2022, alleging a disability onset date of November 17,
2018. (ECF No. 6, PageID #35, #222 & #241–52.) Her claims were denied initially
on July 6, 2023, and on reconsideration on October 5, 2023. (Id. PageID #140–43 &
159–61) On April 9, 2024, Plaintiff was represented by counsel at a hearing before
an administrative law judge. (Id., PageID #35 & #59.) On May 14, 2024, the ALJ
issued a written decision finding Plaintiff not disabled and denying her claims. (Id.,
PageID #35–46.) On February 11, 2025, the Appeals Council denied her request for
review, rendering the administrative law judge’s decision the final decision of the
Commissioner of Social Security. (Id., PageID #26-28.)
A. Evidence Before the Administrative Law Judge
At the hearing before the ALJ on April 9, 2024, the record included the
following facts and materials.
A.1. Relevant Medical Records
On November 2, 2020, Ms. Parise was examined at Doctors Pain Clinic due to
a referral for neck and lower back pain and fibromyalgia. (Id., PageID #581–82.) The
consultation notes of Jason Sindledecker, a nurse practitioner, reflect that Ms. Parise
also experienced bilateral hip and shoulder pain. (Id., PageID #581.) Her history of
present illness included multiple failed attempts at conservative outpatient medical
management, including “physical therapy, non-steroidal anti-inflammatories, mild-
to-moderate analgesics, muscle relaxants, heat and cold therapy, and rest.” (Id.)
On March 16, 2021, Ms. Parise’s boyfriend called EMS because she was not
leaving the house and had high levels of anxiety. (Id., PageID #381.) Reportedly, she
was no longer taking Ativan at the time of the call. (Id.) Upon her arrival to the
emergency room, Ms. Parise refused treatment. (Id.) She stayed in the waiting room
for three hours and then was re-registered for treatment. (Id.) She stated that her
new physician at the time would not administer lorazepam and Percocet. (Id.) She
began taking Suboxone but found that she cannot take pain medication with
Suboxone. (Id.). The treating physician recorded clinical impressions of acute
anxiety, panic disorder, acute paranoia, and delusional disorder. (Id., PageID #385.)
On March 17, 2021, Ms. Parise was admitted to the hospital. (Id., PageID
405.) She was diagnosed with major depressive disorder and panic disorder with
acute agoraphobia and moderate panic attacks. (Id., PageID #409–10.) She was
discharged five days later, on March 22, 2021. (Id., PageID #439.)
At a follow-up appointment on May 25, 2021, Ms. Parise reported being off
Suboxone. (Id., PageID #694.) Her symptoms included anxiety. (Id.) There were no
physical abnormalities in the physical examination portion. (Id.)
At an appointment on September 21, 2021, Ms. Parise was stable on her
medication. (Id., PageID #695.) Her symptoms included anxiety, depression, and
mental illness, as well as joint and muscle pain. (Id.) Results of a physical
examination were normal. (Id.)
On March 28, 2022, Ms. Parise sought medication refills and reported feeling
pressure in her head and ears. (Id., PageID #583.) Her symptoms included anxiety.
(Id.) Results of a physical examination were normal. (Id.)
On July 1, 2022, Karen Anobile, APRN performed a psychiatric evaluation of
Ms. Parise. (Id., PageID #552–58.) She reported having been fired from her most
recent job for being rude to a customer. (Id., PageID #552.) At the time of the
evaluation, she had a job offer at a casino but did not want to accept employment
until she felt better emotionally. (Id.) In a checkbox form, Anobile noted that
Ms. Parise exhibited a depressed and anxious mood, flat affect, cooperative behavior,
and impaired attention and concentration. (Id., PageID #556.) Anobile diagnosed
Ms. Parise with major depressive disorder, generalized anxiety disorder, and a
possible diagnosis of attention hyperactivity disorder. (Id., PageID #558.)
During a follow-up appointment with Anobile on July 29, 2022, Ms. Parise
reported feeling so much better that she was “ready for job hunting.” (Id., PageID
559.) Anobile noted that Ms. Parise’s mood and affect were improved. (Id.) In a
checkbox form, Anobile reported that Ms. Parise exhibited a normal rate of thought
process, a euthymic mood, full affect, normal speech, average behavior, and no
cognitive impairment. (Id., PageID #561.)
On August 4, 2022, Ms. Parise attended an appointment with David Wilhelm,
LSW. (Id., PageID #565–567.) She was reported as doing well with her medications.
(Id., PageID #565.) She felt as though she could begin looking for a job. (Id.) Wilhelm
completed a checkbox form indicating that Ms. Parise’s mood was euthymic and
anxious, and her affect was within the normal range. (Id., PageID #566.)
On August 18, 2022, Ms. Parise met again with Wilhelm. (Id., PageID #568.)
She was doing well with her medications and feeling more motivated. (Id.) Like last
time, Wilhelm checked boxes indicating that Ms. Parise’s mood was euthymic and
anxious, with an affect within the normal range. (Id., PageID #569.)
On October 25, 2022, Dr. Michael Madison evaluated Ms. Parise for chronic
pain, fibromyalgia, and substance use disorder. (Id., PageID #546–51.) Dr. Madison
completed a checkbox form indicating that Ms. Parise exhibited a normal rate of
thought process, euthymic mood, full affect, and no cognitive impairment. (Id.,
PageID #548.) He also recommended that she try medical marijuana. (Id., PageID
550.)
On April 1, 2023, Ms. Parise consulted with Dr. Magid Keramati. (Id., PageID
619–28.) As a result of his physical examination, Dr. Keramati diagnosed Ms. Parise
with a cyst on her left foot, cervical spine tenderness with limited range of motion of
the neck, thoracic spine tenderness, limited mobility of the low back, and bilateral
shoulder pain with limited mobility. (Id., PageID #622.) Dr. Keramati reported that
she was alert, maintained good eye contact, and demonstrated normal memory and
good concentration. (Id., PageID #621.)
On April 20, 2023, Ms. Parise met with Anobile again. (Id., PageID #643–48.)
Anobile reported that Ms. Parise was doing “pretty good” despite her sister’s recent
nonlethal overdose. (Id., PageID #643.) Anobile completed a checkbox form
indicating that Ms. Parise exhibited a normal rate of thought process, a euthymic
mood, full affect, and no cognitive impairment. (Id., PageID #645.)
On June 7, 2023, during a follow-up appointment with Anobile, Ms. Parise
again described feeling “pretty good.” (Id., PageID #630.) Anobile noted that
Ms. Parise was not presently motivated to seek employment. (Id.) On a checkbox
form, Anobile indicated that Ms. Parise had a normal rate of thought process, a
euthymic mood, full affect, and no cognitive impairment. (Id., PageID #632.)
On August 17, 2023, Ms. Parise followed up with Anobile. (Id., PageID
636–41.) Ms. Parise reported that she had filed for disability and that mood swings
and anxiety were “mak[ing] things difficult.” (Id., PageID #636.) Anobile completed
a checkbox form indicating that Ms. Parise exhibited a normal rate of thought
process, a euthymic mood, full affect, and no cognitive impairment. (Id., PageID
638.)
On December 6, 2023, Anobile completed a mental status examination of
Ms. Parise. (Id., PageID #750–751.) The checkbox form indicated that Ms. Parise’s
mood was depressed and anxious, and her affect was flat. (Id., PageID #750.) Anobile
noted that Plaintiff feels “sad this time of year,” and that she feels alone. (Id.)
Anobile also noted that Ms. Parise “continues trying for disability.” (Id.)
On December 27, 2023, Ms. Parise met with Wilhelm again. (Id., PageID
667–69.) She was doing well on her medications, and her sleep had improved. (Id.,
PageID #667.) Ms. Parise was described as unable to work and as having daily panic
attacks. (Id.) Wilhelm completed a checkbox form indicating that Ms. Parise’s mood
was euthymic and anxious, with normal speech and normal-range affect. (Id., PageID
668.)
On January 17, 2024, Ms. Parise followed up with Wilhelm. (Id., PageID
744–46.) She was doing well on her medications but also reported “feeling more
anxious” and “looking to file for disability.” (Id., PageID #744.)
On March 21, 2024, Anobile completed a residual functional capacity form.
(Id., PageID #728–33.) In the RFC, Anobile diagnosed Ms. Parise with paranoia,
panic attacks daily, isolated scattered thoughts, difficulty focusing, difficulty falling
asleep, feeling hopeless with crying spells. (Id., PageID #728.) Anobile opined that
Ms. Parise was unable to work at the time of the exam due to isolation, frequent panic
attacks, depression, and crying spells. (Id.) Anobile also indicated that Ms. Parise
would have problems interacting with others, specifically noting that supervision
would be problematic. (Id., PageID #730.) With respect to adaptation and self-
management, Anobile suggested that Ms. Parise “would have problems with
directions and stamina working a full day.” (Id., PageID #731.) Finally, Anobile
opined that Ms. Parise “would have problems doing any work” due fibromyalgia,
chronic pain, and rheumatoid arthritis. (Id., PageID #733.)
Also on March 21, 2024, Anobile completed a mental status examination of
Ms. Parise. (Id., PageID #752–753.) Anobile completed a checkbox form indicating
that Ms. Parise exhibited a flat affect and depressed mood. (Id., PageID #752.)
On April 18, 2024, Ms. Parise followed up with Anobile. (Id., PageID #738–43.)
She reported being sad. (Id., PageID #738.) She also reported that her anxiety was
at a level of 7 or 8 out of 10 most days and that depression was also high. (Id.) In a
checkbox form, Anobile recorded that Ms. Parise exhibited a normal rate of thought
process, a euthymic mood, and full affect. (Id., PageID #740.) Anobile also checked
boxes indicating that Ms. Parise was alert and oriented, exhibited normal speech,
average demeanor, and that no cognitive impairment was reported or observed. (Id.)
In that same form, Anobile indicated that Ms. Parise had no suicidal or homicidal
ideation, no hallucinations or delusions, and that she had good insight. (Id., PageID
741.)
A.2. Prior State Agency Administrative Medical Findings
On June 30, 2023, Dr. Craig Billinghurst, a consulting physician for a State
agency, evaluated Ms. Parise’s residual functional capacity. (Id., PageID #103–05.)
Dr. Billinghurst opined that Ms. Parise’s overhead reaching was limited. (Id., PageID
104.) Her bilateral upper extremities were limited to occasional overhead reaching.
(Id.) These findings were submitted for reconsideration to Dr. Leon Hughes, another
State agency consulting physician. (Id., PageID #129–39.) On October 2, 2023,
Dr. Hughes confirmed that Ms. Parise’s bilateral upper extremities were limited to
occasional overhead reaching. (Id., PageID #136.)
A.3. Ms. Parise’s Testimony
During the April 9, 2024 hearing, Ms. Parise testified that she was last
employed in 2018 as a casino dealer. (Id., PageID #67–68.) Before that, she worked
as a hairdresser. (Id.)
Further, Ms. Parise testified that she had fibromyalgia and rheumatoid
arthritis and that these conditions caused her daily pain. (Id., PageID #72–73.) She
indicated that she was presently “in a major dark depression” and had been for six
months. (Id., PageID #75.) Also, she reported daily panic attacks. (Id., PageID #79.)
Ms. Parise testified that she rarely drives due to anxiety and that she receives
rides to her appointments. (Id., PageID #67.) In the previous month, she went
shopping three times with her sister. (Id., PageID #77.) She reported difficulty
watching television due to attention deficit hyperactivity disorder. (Id., PageID
79–80.)
A.4. Testimony of Vocational Expert
Deborah Lee, a vocational expert, testified regarding Ms. Parise’s past work as
a casino dealer and hairdresser. (Id., PageID #82). Also, the expert answered a series
of hypothetical questions involving persons with a similar residual functional
capacity to Ms. Parise. (Id., PageID #82–87.) The vocational expert testified that
there are suitable “light and unskilled” occupational profiles for someone of
Ms. Parise’s age, education, background, work experience, and psychological and
physical condition. (Id., PageID #84–86.) Specifically, the expert estimated
approximately 38,000 positions as a mail clerk in the national economy, as well as
approximately 84,000 positions as an office helper and 83,000 positions as an
inspector hand packager. (Id.)
B. The ALJ’s Decision
After reviewing the evidence, the administrative law judge conducted the
familiar five-step analysis set forth in 20 C.F.R. § 404.1520 (a)(4) and determined that
Ms. Parise is not disabled. (Id., PageID #35–46.)
At step one, the ALJ found that the Ms. Parise has not engaged in substantial
gainful activity since November 17, 2018, the alleged onset date of her claimed
disability. (Id., PageID #37.)
At step two, the administrative law judge found that the claimant has the
following severe impairments: panic disorder with agoraphobia, major depressive
disorder, anxiety disorder, posttraumatic stress disorder, fibromyalgia, cervicalgia,
chronic pain syndrome, arthropathy, and lumbar spine degenerative disc disease.
(Id., PageID #37–38.) The ALJ found that Ms. Parise’s rheumatoid arthritis is a non-
medically determinable impairment because there was no formal diagnosis or related
treatment for this condition found in the record. (Id., PageID #38.)
At step three, the ALJ found that Ms. Parise does not have an impairment or
combination of impairments that meets or medically equals the severity of one of the
listed impairments in 20 C.F.R. Part 404, Subpart P, Appendix 1 (20 C.F.R.
§§ 404.1520 (d), 404.1525, 404.1526, 416.920(d), 416.925 & 416.926). (Id.)
With respect to mental impairments, the ALJ considered whether the
Paragraph B criteria for mental impairment were satisfied. (Id., PageID #39.) The
satisfaction of Paragraph B criteria requires an extreme limitation of one, or a
marked limitation of two, areas of mental functioning. See 20 C.F.R. § 404.1520. The
ALJ found that in understanding, remembering, or applying information, Ms. Parise
has a mild limitation. (Id., PageID #39.) In interacting with others, her limitation is
moderate. (Id.) Her limitations in concentrating, persisting, or maintaining pace as
well as adapting or managing herself are also moderate. (Id.) The ALJ attributed
these findings to the results of Ms. Parise’s various mental status examinations, her
testimony, and the evidentiary record as a whole. (Id., PageID #39.) The ALJ
considered Ms. Parise’s mental limitations and opined that her mental impairments
did not include two marked limitations or one extreme limitation, prompting the ALJ
to find that the Paragraph B criteria were not satisfied. (Id.)
Before considering step four, the ALJ found that Ms. Parise had the residual
functional capacity to perform light work:
[T]he claimant has the residual functional capacity to perform light
work as defined in 20 CFR 404.1567(b) and 416.967(b) except she can
frequently balance, crouch, kneel, and stoop; occasionally climb ramps
and stairs, and crawl, but can never climb ladders, ropes, or scaffolds;
can frequently reach overhead, in front and laterally, bilaterally; no
work around unprotected heights or dangerous moving machinery;
cannot perform work requiring specific production rate like assembly
line work or work requiring hourly quotas; can understand, remember,
and carry out simple, detailed, but not complex instructions; can deal
with occasional changes in a routine work setting; can occasionally
interact with supervisors and coworkers in a non-public work setting;
and due to the claimant’s mental health symptoms and impairments,
she would be absent one day per month.
(Id., PageID #40.)
In making this determination, the ALJ considered “all symptoms and the
extent to which these symptoms can reasonable be accepted as consistent with the
objective medical evidence and other evidence,” in addition to “the medical opinion(s)
and prior administrative medical findings.” (Id.) The ALJ stated that Ms. Parise’s
medically determinable impairments could reasonably be expected to cause the
alleged symptoms, but her statements concerning the intensity, persistence and
limiting effects of these symptoms are “not entirely consistent” with the evidence in
the record. (Id., PageID #43.) The ALJ additionally assessed the persuasiveness of
the various medical providers whose assessments of Ms. Parise’s medical and
physical functionality are included in the record. (Id., PageID #43.)
At step four, the ALJ found that Ms. Parise was unable to perform any past
relevant work. (Id., PageID #44.) In support of this determination, the ALJ pointed
to the testimony of the vocational expert, finding that “the demands of the plaintiff’s
past relevant work exceed the above residual functional capacity.” (Id.)
Finally, at step five, the ALJ found that “there are jobs that exist in significant
numbers in the national economy that the claimant can perform.” (Id.) The ALJ
considered Ms. Parise’s age, education, work experience, and residual functional
capacity in making its determination. (Id.) Using the above factors, the ALJ
concluded that Plaintiff would be able to perform a “significant number of jobs in the
national economy.” (Id., PageID #45.)
ANALYSIS
Under 42 U.S.C. § 405 (g), the findings of an administrative law judge are
conclusive if substantial evidence supports them. Therefore, the Court limits its
review to determining whether substantial evidence in the record supports the
Commissioner’s decision and to reviewing any claimed legal errors de novo. Wright
v. Massanari, 321 F.3d 611, 614–15 (6th 2003). “Substantial evidence” is more than
a scintilla, but less than a preponderance. Rogers v. Commissioner of Soc. Sec., 486
F.3d 234, 241 (6th Cir. 2007). Substantial evidence is relevant evidence that “a
reasonable mind might accept as adequate to support a conclusion.” Id. If
substantial evidence supports the Commissioner’s findings, then the Court accepts
them as conclusive, even if it would have reached a different outcome on the same
facts. 42 U.S.C. § 405 (g).
Plaintiff maintains that the administrative law judge “failed to account for the
‘total limiting effects’ of Plaintiff’s impairments pursuant to 20 C.F.R. §§ 404.1520c,
404.1529, and 404.1545(e), resulting in a decision that is not supported by substantial
evidence.” (ECF No. 7, PageID #754.) Specifically, Plaintiff argues that the ALJ’s
finding of her residual functional capacity “does not sufficiently account” for the
limitations outlined that Anobile outlined and her vocational limitations. (Id.,
PageID #767.) Plaintiff focuses primarily on the ALJ’s finding that Anobile was
unpersuasive, contending that “the ALJ’s analysis of Nurse Anobile’s opinion is not
supported by substantial evidence.” (Id.) Then, Plaintiff argues that “substantial
evidence does not support that she can lift up to 20 pounds, as light work requires, or
stand and walk for up to six hours in an eight-hour workday, at least not without the
option to frequently alternate positions.” (Id., PageID #768.) Plaintiff argues that
these errors together constitute the ALJ’s failure to account for the “total limiting
effects” of Plaintiff’s impairments. (Id.)
I. Nurse Anobile
The ALJ concluded that Anobile’s opinion was unpersuasive because it
“provided little explanation or supporting evidence” and was “inconsistent with the
medical record as a whole.” (ECF No. 6, PageID #43.) Plaintiff argues that Anobile’s
opinion was supported, as 20 C.F.R. § 404.1520c(b)(2) requires, and was consistent
with the medical record. (ECF No. 7, PageID #770 & #772.)
However, in the medical record one finds notable differences between Anobile’s
assessment of Ms. Parise’s cognitive and mental health outlook on March 21, 2024
(the date of the RFC opinion) and the notes of Ms. Parise’s other providers, which
report effective results with medication and significant overall symptomatic
improvements. (See e.g., ECF No. 6, PageID #565, #568, #630, #667, #695 & #744.)
Additionally, on dates other than March 21, 2024, Anobile’s notes often echoed those
more positive reports Ms. Parise and reflect progress and success with medication.
(Id., PageID #559, #643 & #630.) These discrepancies amount to substantial evidence
of inconsistency.
Also, the Court notes that several of the relevant reports from Anobile were
checkbox forms lacking any description or narrative summary about Ms. Parise’s
condition. (Id., PageID #552–64, #630–41, #729, #752–53.) The Sixth Circuit has
held that check-box forms, which only require an individual to check a box or fill in
blanks that lack other narrative or explanation, are conclusory opinions that amount
to “weak evidence at best.” Hernandez v. Commissioner of Soc. Sec., 644 F. App'x 468,
474 (6th Cir. 2016) (citing Mason v. Shalala, 994 F.2d 1058, 1065 (3d Cir. 1993)). To
the extent that the ALJ gave these documents lesser weight in making her disability
determination, she acted properly.
Plaintiff challenges the ALJ’s finding that Anobile’s opinion is inconsistent
with Ms. Parise’s “varied activities of daily living.” (ECF No 7, PageID #773 (quoting
ECF No. 6, PageID #43).) She characterizes this phrase as “so vague as to render
meaningful judicial review impossible.” (ECF No. 7, PageID #773.) However, the
Court is not “left to guess as to what the ALJ meant by ‘varied activities of daily
living’” because the term has specific meaning in the context of care and treatment
relating to a person’s physical condition and litigation about the same. In any event,
the ALJ expressly references those activities described earlier in her opinion. (ECF
No. 7, PageID# 774; ECF No. 6, PageID #43–44.) For example, the ALJ described
Ms. Parise’s relevant activities of daily living:
Regarding activities of daily living, claimant testified that she has a
driver’s license and is able to drive, but she rarely drives due to anxiety
fears, she usually gets rides to appointments, and she currently lives
with her friend and pet cat. Finally, she said that she goes grocery
shopping with her sister roughly three times per month, she last worked
in 2019 for Door Dash, and she has difficulty watching television due to
lack of concentration stemming from ADHD.
(ECF No. 6, PageID #41.) Additionally, the ALJ notes that Ms. Parise reported caring
for her sister’s cats and 17-year-old son while her sister was in rehabilitation. (Id.,
PageID #42–43.) This latter report came on April 28, 2024, nearly one month after
Anobile completed her residual functional capacity on March 21, 2024 and found that
Ms. Parise would be off task 100 percent of the workday, could not sustain work
activity, and would miss more than four workdays per month due to her
immurements. (Id., PageID #728-33, 738.) The ALJ considered Ms. Parise’s reported
activities to be inconsistent with Anobile’s opinion. (Id., PageID #43.) The Court
finds that this portion of the ALJ’s analysis does not involve impermissible post-hoc
rationalization, as Plaintiff argues. (ECF No. 10, PageID #798.)
Also, Plaintiff argues that the ALJ imposed an “implicit requirement that
Nurse Anobile needed to provide objective evidence to support her opinion regarding
subjectively experienced [mental health] impairments.” (ECF No. 7, PageID #772.)
But the ALJ merely weighed the most important factors of consistency and
supportability to evaluate the persuasiveness of Anobile’s opinion. (ECF No. 6,
PageID # 43–44.) In doing so, the ALJ found that Anobile’s opinion conflicted with
other evidence, such as “claimant’s significant improvement from her counseling
sessions and psychiatric medications.” (Id., PageID #43.) Far from imposing
impermissible requirements, the ALJ’s explanation reflects a process faithful to the
requirements of the Social Security Act. See 20 C.F.R. § 404.1520c(b)(2).
In reply, Plaintiff argues that the ALJ’s supportability analysis did not account
for the psychiatric signs that existed to support Anobile’s position or reflect evidence
of Ms. Parise’s symptoms and medications or of Anobile’s supporting explanations.
(ECF No. 10, PageID #796 & #798.) Nothing in the record suggests that the ALJ did
not consider this evidence when making her determination. The ALJ “set forth her
rationale on what are deemed to be the most two important factors—supportability
and consistency.” Lorie B v. Commissioner of Soc. Sec. Admin., No. 2:22-cv-2632, 2023 WL 6318074, at *4 (S.D. Ohio Sept. 28, 2023). The Court determines that the
ALJ provided sufficient evidence to support her findings regarding Anobile’s medical
and opinion evidence.
II. Vocational Expert
Plaintiff highlights the vocational expert’s testimony that being absent more
than once a month and being off task more than 20% of the day are limitations that
preclude work. (ECF No. 7., PageID #766–67; ECF No. 6, PageID #86–88.) Still, the
vocational expert ultimately testified that there are suitable “light and unskilled”
occupational profiles for someone of Ms. Parise’s age, education, background, work
experience, and psychological and physical condition. (Id., PageID #84–85.) Taking
the vocational expert’s testimony together with Anobile’s opinion, the ALJ found that
Ms. Parise was able to work in several occupations, precluding a finding of disability.
Substantial evidence supports this decision of the administrative law judge.
III. State Agency Medical Consultants
Plaintiff argues that the ALJ erred because she did not address the limitation
for overhead reaching that Dr. Billinghurst and Dr. Hughes identified. (ECF No. 7,
PageID #768.) In response, the Commissioner points out that the ALJ asked the
vocational expert a hypothetical question that encompassed this limitation. (ECF
No. 9, PageID #787.) The vocational expert’s response noted that the Dictionary of
Occupational Titles does not specifically reference limitations in overhead reaching.
(Id., see also ECF No. 6, PageID #87.)
The Court agrees with the Commissioner. The ALJ’s questioning of the
vocational expert acknowledged the limitations that Dr. Billinghurst and Dr. Hughes
identified. (ECF No. 6, PageID #87, #104 & #136.) Having been informed of
Ms. Parise’s occasional overhead reach limitation, the vocational expert still found
that she could work as a mail clerk, office helper, and inspector hand packager. (Id.,
PageID #84 & #86.) The vocational expert estimated that the number of available
positions in each of these fields totaled 38,000, 84,000, and 83,000, respectively. (Id.)
Accordingly, the Court discerns no reversible error.
IV. Self-Described Limitations
Plaintiff argues that the ALJ could not have properly evaluated her self-
described limitations because the ALJ did not adequately consider the medical
opinion evidence, specifically that of Anobile and Drs. Billingshurst and Hughes.
(ECF No. 10, PageID #799.) Because the ALJ adequately considered the medical
opinion evidence, this argument misses the mark. Moreover, the record demonstrates
that the ALJ evaluated Plaintiff’s claims in relation to the medical evidence and
opinions in the record. The ALJ’s decision engaged with the record extensively,
comparing Plaintiff’s claims of disabling limitations to, for example, Ms. Parise’s
conservative treatment history for physical health impairments and the
unremarkable results of Dr. Magid Keramati’s thorough physical examination (ECF
No. 6, PageID #42-43 & #621—28.) In short, the ALJ provided substantial evidence
to support a finding that Plaintiffs physical and mental impairments did not satisfy
the criteria for any listed impairment.
CONCLUSION
For the foregoing reasons, the Court AFFIRMS the Commissioner’s denial of
Plaintiff's applications for disability insurance benefits and supplemental security
income benefits.
SO ORDERED.
Dated: March 27, 2026
J.PhilipCalabrese
United States District Judge
Northern District of Ohio
18
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