Dawn Mabry-Schlicher v. Comm'r of Soc. Sec.
Court
Sixth Circuit Court of Appeals
Decided
June 6, 2025
Jurisdiction
F
Practice Areas
Case Summary
NOT RECOMMENDED FOR PUBLICATION File Name: 25a0278n.06 No. 24-3811 UNITED STATES COURT OF APPEALS FOR THE SIXTH CIRCUIT FILED Jun 06, 2025 DAWN MABRY-SCHLICHER, ) KELLY L. STEPHENS, Clerk ) Plaintiff-Appellant, ) ) ON APPEAL FROM THE UNITED v. ) STATES DISTRICT COURT FOR ) THE SOUTHERN DISTRICT OF COMMISSIONER OF SOCIAL ) OHIO SECURITY, ) Defendant-Appellee. ) OPINION ) Before: CLAY, KETHLEDGE, and STRANCH, Circuit Judges. JANE B. STRANCH, Circuit Judge. Dawn Mabry-Schlicher applied for disability benefits based on severe anxiety and depression, among other disabilities. After the Social Security Administration (SSA) rejected the application, the district court remanded the application to the agency with instructions to further consider medical testimony regarding Mabry-Schlicher’s social impairments. On remand, the SSA again rejected Mabry-Schlicher’s application, and the district court affirmed. Mabry-Schlicher contends that the SSA failed to comply with the district court’s remand order and ignored important vocational testimony. For the reasons set forth below, we AFFIRM the judgment of the district court. I. BACKGROUND Mabry-Schlicher alleges disability secondary to various impairments, including, among other things, depression, anxiety, fibromyalgia, obesity, foot injury and degeneration, and recurrent migraines. Because of her mental disabilities and migraines, Mabry-Schlicher has difficulty No. 24-3811, Mabry-Schlicher v. Comm’r of Soc. Sec. interacting with others and is wary of leaving her home. She also struggles with mobility and experiences frequent pain due to her physical disabilities. Mabry-Schlicher applied to the SSA for disability insurance benefits (DIB) and supplemental security income (SSI) in May 2015. In evaluating her application, the agency reviewed copies of Mabry-Schlicher’s medical records, as well as various expert evaluations and opinions. These included a psychological evaluation from Dr. Giovanni M. Bonds, who found that Mabry-Schlicher “avoid[s] people and socializing with them” and “would have difficulty working around many people.” R. 7-7, PageID 407. Another psychologist, Dr. Karen Steiger, also conducted an evaluation, determining that Mabry-Schlicher’s ability to interact with coworkers was “[m]oderately limited,” and that any such interaction should be kept to “a superficial level,” while “contact with the general public should be kept to a limited basis.” R. 7-3, PageID 119. Two other psychologists, Dr. Joseph Edwards and Dr. Courtney Zeune, similarly determined that Mabry-Schlicher was “[m]oderately limited” in her ability to interact with coworkers, but remained capable of “infrequent, superficial interactions” with others. Id. at PageID 149, 182. The SSA denied the May 2015 claim, concluding that Mabry-Schlicher was not “disabled” within the meaning of the Social Security Act. Seeking reversal of the denial, Mabry-Schlicher requested a hearing before an administrative law judge (ALJ), which was held on October 3, 2017. At the hearing, the ALJ heard testimony from Mabry-Schlicher, as well as a vocational expert, Karen Schneider. Schneider testified that it is “important” that all employees “respond appropriately to instructions and accept supervisor criticism,” and stated that she would not characterize supervisory criticism as “superficial.” R. 7-2, PageID 102. The ALJ denied the -2- No. 24-3811, Mabry-Schlicher v. Comm’r of Soc. Sec. claim, and Mabry-Schlicher appealed to the district court. On the joint motion of the parties, the district court remanded the case to the SSA for further proceedings. On remand, the case was reassigned to a new ALJ, who held a second hearing on February 5, 2020. The ALJ again heard personal testimony from Mabry-Schlicher and vocational testimony from Schneider, and concluded that Mabry-Schlicher was not disabled. Notably, the ALJ’s decision discounted the opinions of the reviewing psychologists that Mabry-Schlicher maintained the ability to interact with coworkers and officials at only a “superficial” level, deeming th
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Case Details
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Status
Decided
Date Decided
June 6, 2025
Jurisdiction
F
Court Type
appellate
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Case Summary
AI-generated comprehensive summary with legal analysis
Case Overview
Dawn Mabry-Schlicher v. Comm'r of Soc. Sec. is a significant case decided by the Court of Appeals for the Sixth Circuit on June 6, 2025. This case revolves around the appeal of Mabry-Schlicher concerning the denial of her disability benefits by the Social Security Administration (SSA), following a remand from the district court for further evaluation of her social impairments.
Legal Issues
The primary legal questions addressed in this case include:
- Whether the SSA complied with the district court's remand order regarding the assessment of 'superficial' limitations.
- Whether the Administrative Law Judge (ALJ)'s decision adhered to the remand order concerning the superficial contact limitation.
- Whether the ALJ erred by not addressing significant vocational expert testimony from 2017.
Factual Background
- Mabry-Schlicher suffers from multiple impairments, including anxiety, depression, and various physical disabilities, which are central to her claim for disability benefits.
- The ALJ determined that she could perform sedentary work with a limitation on superficial contact, allowing for occasional interaction with supervisors and coworkers but no interaction with the general public.
- The district court previously remanded the case for further consideration of her social impairments, particularly focusing on the definition and implications of superficial interactions.
Court's Analysis
The court's reasoning can be summarized as follows:
- The district court found that the ALJ's interpretation of 'superficial' interactions was adequate and did not violate the remand order. The ALJ's definition was deemed clear and relevant to vocational assessments.
- The ALJ's decision complied with the remand order, as the term 'superficial' was recognized and incorporated into the Residual Functional Capacity (RFC) determination, despite the ALJ's concerns about its vagueness.
- The court noted that the ALJ is not required to address every piece of evidence in the record, and the omission of the 2017 vocational testimony was not an error, as the remand order did not mandate its consideration.
Holdings and Decision
The court upheld the following key rulings:
- The judgment of the district court affirming the ALJ's decision is upheld, confirming that the interpretation of 'superficial' limitations was appropriate and did not constitute an error.
- The ALJ's decision was compliant with the district court's remand order, and the findings were supported by substantial evidence.
Legal Precedents
Several important cases were cited in the court's analysis:
- Hamilton v. Comm’r of Soc. Sec., 98 F.4th 800 (6th Cir. 2024): Establishes the standard of review for decisions denying disability benefits.
- Arizona v. California, 460 U.S. 605 (1983): Governs subsequent stages in the same case.
- Youghiogheny & Ohio Coal Co. v. Milliken, 200 F.3d 942 (6th Cir. 1999): Affirms that administrative agencies must follow federal court orders.
- Loral Def. Sys.-Akron v. NLRB, 200 F.3d 436 (6th Cir. 1999): Establishes that an ALJ does not need to address every piece of evidence.
Practical Implications
This case has significant implications for:
- Social Security Law and Disability Law, particularly regarding the assessment of vocational limitations and the interpretation of superficial interactions in the context of disability claims.
- Future cases may reference this ruling to clarify the standards for ALJ compliance with remand orders and the treatment of vocational testimony in disability determinations.
Overall, the court's decision reinforces the importance of substantial evidence in administrative law and the discretion afforded to ALJs in interpreting complex limitations in disability cases.
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Case Details
Legal case information
Status
Decided
Date Decided
June 6, 2025
Jurisdiction
F
Court Type
appellate
Legal Significance
Case importance metrics
Metadata
Additional information
Quick Actions
Case management tools