Watson v. Commissioner of the Social Security Administration

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Case: 4:25-cv-00287-DCN Doc #: 16 Filed: 12/01/25 1 of 4. PagelD #: <pagelD>

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF OHIO

EASTERN DIVISION
STARR WATSON, ) Case No. 4:25-—CV—00287
)
Plaintiff, )
) JUDGE DONALD C. NUGENT
v. )
)
COMMISSIONER OF THE SOCIAL ) Magistrate Judge James E. Grimes Jr.
SECURITY ADMINISTRATION, )
)
Defendant. ) MEMORANDUM OPINION

This matter is before the Court upon the Report and Recommendation issued by
Magistrate Judge James E. Grimes Jr. on August 27, 2025. (ECF #15).

In April 2022, plaintiff Starr Watson (“Watson”) applied for supplemental security
income. (/d. at p.1 [PageID #1239]). An Administrative Law Judge (“ALJ”) denied Mrs.
Watson’s application on September 13, 2023. (ECF #1, Complaint, p.2 4 7 [PageID #2]). She
appealed that decision to the Appeals Council, which denied review of the ALJ’s decision on
October 21, 2024. Ud. at p.2 9 8 [PageID #2]). The Appeals Council’s denial of benefits
ultimately became the Commissioner’s final decision. See 20 C.F.R. § 404.981. Mrs. Watson
filed the instant Complaint challenging the denial of benefits on February 13, 2025. (ECF #1,
Complaint). Objections to the Report and Recommendation were to be filed by September 10,

2025. No objections were filed.

on IENTICATED
U.S. GOVERNMENT

INFORMATION
GPO

Case: 4:25-cv-00287-DCN Doc #: 16 Filed: 12/01/25 2 of 4. PagelD #: <pagelD>

Standard of Review for a Magistrate Judge’s Report and Recommendation

The applicable district court standard of review for a magistrate judge’s report and
recommendation depends on whether objections were made to that report. When objections are
made to a magistrate judge’s report and recommendation, the district court reviews the case de
novo. Fed. R. Civ. P. 72(b)(3) provides that:

The district judge must determine de novo any part of the magistrate
judge’s disposition that has been properly objected to. The district
judge may accept, reject, or modify the recommended disposition;
receive further evidence; or return the matter to the magistrate judge
with instructions.

The text of Rule 72(b) addresses only the review of reports to which objections have been
made; it does not indicate the appropriate standard of review for reports to which no objections
have been properly made. The Advisory Committee on Civil Rules commented on a district
court’s review of unopposed reports by magistrate judges. The Advisory Committee noted with
respect to subsection (b) of Rule 72 that: “When no timely objection is filed, the court need only
satisfy itself that there is no clear error on the face of the record in order to accept the
recommendation.” Fed. R. Civ. P. 72 Advisory Committee’s Notes (citation omitted).

The United States Supreme Court stated in Thomas v. Arn, 474 U.S. 140, 150 (1985): “It
does not appear that Congress intended to require district court review of a magistrate judge’s
factual or legal conclusions, under a de novo or any other standard, when neither party objects to
those findings.”

Conclusion

The Court has reviewed Magistrate Judge James E. Grimes Jr.’s Report and

Recommendation and agrees with the findings set forth therein.

Case: 4:25-cv-00287-DCN Doc #: 16 Filed: 12/01/25 3 of 4. PagelD #: <pagelD>

Mrs. Watson raised, before the issuance of the Report and Recommendation, two primary
arguments suggesting error on behalf of the ALJ when he denied her application for
supplemental security income. Both of which were correctly addressed and dispensed with in the
comprehensive Report and Recommendation issued by Magistrate Judge Grimes.

Her first argument alleges that the assessment of her Residual Functional Capacity was
not supported by substantial evidence because it was based solely on the ALJ’s lay opinion.
According to Mrs. Watson, she appears to argue that the ALJ must have based his conclusion on
his lay opinion because he rejected the only medical opinion of record. As a result, she claims the
ALJ had a duty to further develop the record. Magistrate Judge Grimes correctly noted that
Moats v. Comm’r of Soc. Sec., 42 F.4th 558 (6th Cir. 2022) established the controlling law
pertaining to when an ALJ has a duty to develop the record, which exists in “extreme
circumstances” not present in Mrs. Watson’s case. Further, the record reflects that the ALJ relied
on other sources, including state psychological consultants, when reaching his decision. The
ALJ’s conclusion, as noted by Magistrate Judge Grimes, can hardly be said to have relied only
on his lay opinion.

Mrs. Watson’s second argument was that the ALJ erred because he failed, at step five of
the sequential evaluation process, to identify the jobs that exist in significant numbers in the
national economy. The ALJ found that three different jobs were available to Mrs. Watson in
significant numbers: (1) examiner, (2) folder, and, (3) document clerk. (ECF #15, p.16—17).
Regarding the final category, Mrs. Watson made an untimely argument that the position was
obsolete; however, because she did not raise the issue before the agency, she forfeited this

argument.

Case: 4:25-cv-00287-DCN Doc #: 16 Filed: 12/01/25 4 of 4. PagelD #: <pagelD>

With respect to all three jobs, the ALJ found that 58,000 were available, which the ALJ
deemed a “significant” number. Magistrate Judge Grimes agreed, citing cases where 18,800,
6,000, and, 2,000 jobs were considered significant. Norris v. Comm’r of Soc. Sec., 139 F.4th 541,
546 (6th Cir. 2025); Taskila v. Comm’r of Soc. Sec., 819 F.3d 902, 905 (6th Cir. 2016); Nejat v.
Comm’r of Soc. Sec., 359 F. App’x 574, 579 (6th Cir. 2009).

Further, Magistrate Judge Grimes correctly dispensed with Mrs. Watson’s argument that
the ALJ improperly assessed whether significant numbers of the three categories of jobs existed.
Mrs. Watson argued that the ALJ should have considered every factor in Hall v. Bowen, 837 F.2d
272 (6th Cir. 1988), factors which Magistrate Judge Grimes correctly noted are “suggestions
only—the ALJ need not explicitly consider each factor.” Harmon v. Apfel, 168 F.3d 289, 292 (6th
Cir. 1999).

Accordingly, the Report and Recommendation of Magistrate Judge James E. Grimes Jr.,
(ECF #15), is hereby ADOPTED. The final decision of the Commissioner denying plaintiff Starr
Watson’s application for supplemental security income is hereby AFFIRMED.

This case is hereby TERMINATED.

ITIS SO ORDERED.

DONALD C: ka
United States ae

DATED: Neal 1%, lors