AGNEW JR. v. KIJAKAZI

CourtDistrict Court, S.D. Indiana
DecidedSeptember 22, 2021
Docket1:20-cv-01993
StatusUnknown

This text of AGNEW JR. v. KIJAKAZI (AGNEW JR. v. KIJAKAZI) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
AGNEW JR. v. KIJAKAZI, (S.D. Ind. 2021).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

EZELL A.,1 ) ) Plaintiff, ) ) v. ) No. 1:20-cv-1993-JMS-MG ) KILOLO KIJAKAZI, Acting Commissioner of the ) Social Security Administration,2 ) ) Defendant. )

ENTRY REVIEWING THE COMMISSIONER'S DECISION

Plaintiff Ezell A. filed for supplemental security income ("SSI") from the Social Security Administration ("SSA") on September 26, 2017, alleging an onset date of October 1, 2010. [Filing No. 10-3 at 1.] His application was denied initially, [Filing No. 10-2 at 51-60], and upon reconsideration, [Filing No. 10-2 at 61-73]. Administrative Law Judge ("ALJ") Monica LaPolt conducted a hearing on July 22, 2019, [Filing No. 10-2 at 28-50], before issuing a decision on August 21, 2019, concluding that Ezell A. was not entitled to receive benefits, [Filing No. 10-2 at 15-22]. The Appeals Council denied review on June 8, 2020. [Filing No. 10-2 at 1.] Ezell A. timely filed this civil action asking the Court to review the denial of benefits pursuant to 42 U.S.C. §§ 405(g) and 1383(c). [Filing No. 1.]

1 To protect the privacy interests of claimants for Social Security benefits, consistent with the recommendation of the Court Administration and Case Management Committee of the Administrative Office of the United States courts, the Southern District of Indiana has opted to use only the first name and last initial of non-governmental parties in its Social Security judicial review opinions.

2 According to Federal Rule of Civil Procedure 25(d), after the removal of Andrew M. Saul from his office as Commissioner of the SSA on July 9, 2021, Kilolo Kijakazi automatically became the Defendant in this case when she was named as the Acting Commissioner of the SSA. I. STANDARD OF REVIEW

"The Social Security Administration (SSA) provides benefits to individuals who cannot obtain work because of a physical or mental disability." Biestek v. Berryhill, 139 S. Ct. 1148, 1151 (2019). Disability is the inability "to engage in 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 twelve months." Stephens v. Berryhill, 888 F.3d 323, 327 (7th Cir. 2018) (citing 42 U.S.C. § 423(d)(1)(A)). When an applicant appeals an adverse benefits decision, this Court's role is limited to ensuring that the ALJ applied the correct legal standards and that substantial evidence exists for the ALJ's decision. Stephens, 888 F.3d at 327. "[S]ubstantial evidence" is such relevant "evidence that 'a reasonable mind might accept as adequate to support a conclusion.'" Zoch v. Saul, 981 F.3d 597, 601 (7th Cir. 2020) (quoting Biestek, 139 S. Ct. at 1154). "Although this Court reviews the record as a whole, it cannot substitute its own judgment for that of the SSA by reevaluating the facts, or reweighing the evidence to decide whether a claimant is in fact disabled." Stephens, 888 F.3d at 327. Reviewing courts also "do not decide questions of credibility, deferring instead to the ALJ's conclusions unless 'patently wrong.'" Zoch, 981 F.3d at 601 (quoting Summers v. Berryhill, 864 F.3d 523, 528 (7th Cir. 2017)). The Court does

"determine whether the ALJ built an 'accurate and logical bridge' between the evidence and the conclusion." Peeters v. Saul, 975 F.3d 639, 641 (7th Cir. 2020) (quoting Beardsley v. Colvin, 758 F.3d 834, 837 (7th Cir. 2014)). The SSA applies a five-step evaluation to determine whether the claimant is disabled. Stephens, 888 F.3d at 327 (citing 20 C.F.R. § 404.1520(a)(4); 20 C.F.R. § 416.920(a)(4)). The ALJ must evaluate the following, in sequence: (1) whether the claimant is currently [un]employed; (2) whether the claimant has a severe impairment; (3) whether the claimant's impairment meets or equals one of the impairments listed by the [Commissioner]; (4) whether the claimant can perform [his] past work; and (5) whether the claimant is capable of performing work in the national economy.

Clifford v. Apfel, 227 F.3d 863, 868 (7th Cir. 2000), as amended (Dec. 13, 2000) (citations omitted).3 "If a claimant satisfies steps one, two, and three, [he] will automatically be found disabled. If a claimant satisfies steps one and two, but not three, then [he] must satisfy step four. Once step four is satisfied, the burden shifts to the SSA to establish that the claimant is capable of performing work in the national economy." Knight v. Chater, 55 F.3d 309, 313 (7th Cir. 1995). After Step Three, but before Step Four, the ALJ must determine a claimant's residual functional capacity ("RFC") by evaluating "all limitations that arise from medically determinable impairments, even those that are not severe." Villano v. Astrue, 556 F.3d 558, 563 (7th Cir. 2009). In doing so, the ALJ "may not dismiss a line of evidence contrary to the ruling." Id. The ALJ uses the RFC at Step Four to determine whether the claimant can perform his own past relevant work and if not, at Step Five to determine whether the claimant can perform other work. See 20 C.F.R. § 404.1520(a)(4)(iv), (v).

3 The Code of Federal Regulations contains separate, parallel sections concerning SSI and disability insurance benefits ("DIB"), which are identical in most respects. Cases may reference the section pertaining to DIB, such as in Clifford, which cites 20 C.F.R. § 404.1520. 227 F.3d at 868. Generally, a verbatim section exists establishing the same legal point with both types of benefits. See, e.g., 20 C.F.R. § 416.920. The Court will usually not reference the parallel section but will take care to detail any substantive differences applicable to the case. If the ALJ committed no legal error and substantial evidence exists to support the ALJ's decision, the Court must affirm the denial of benefits. Stephens, 888 F.3d at 327. When an ALJ's decision does not apply the correct legal standard, a remand for further proceedings is usually the appropriate remedy. Karr v. Saul, 989 F.3d 508, 513 (7th Cir. 2021). Typically, a

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Sullivan v. Zebley
493 U.S. 521 (Supreme Court, 1990)
Villano v. Astrue
556 F.3d 558 (Seventh Circuit, 2009)
Cheryl Beardsley v. Carolyn Colvin
758 F.3d 834 (Seventh Circuit, 2014)
Mildred Thomas v. Carolyn Colvin
745 F.3d 802 (Seventh Circuit, 2014)
Daniel Minnick v. Carolyn Colvin
775 F.3d 929 (Seventh Circuit, 2015)
Gotoimoana Summers v. Nancy A. Berryhill
864 F.3d 523 (Seventh Circuit, 2017)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Gerald Peeters v. Andrew Saul
975 F.3d 639 (Seventh Circuit, 2020)
Chic Zoch v. Andrew Saul
981 F.3d 597 (Seventh Circuit, 2020)
Jennifer Karr v. Andrew Saul
989 F.3d 508 (Seventh Circuit, 2021)
Stephens v. Berryhill
888 F.3d 323 (Seventh Circuit, 2018)

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AGNEW JR. v. KIJAKAZI, Counsel Stack Legal Research, https://law.counselstack.com/opinion/agnew-jr-v-kijakazi-insd-2021.