Barnes v. Commissioner of Social Security

CourtDistrict Court, S.D. Illinois
DecidedSeptember 26, 2025
Docket3:24-cv-00287
StatusUnknown

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

Bluebook
Barnes v. Commissioner of Social Security, (S.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

SHARDAE B.,1 ) ) Plaintiff, ) ) vs. ) Case No. 3:24-CV-287-MAB2 ) COMMISSIONER OF SOCIAL ) SECURITY, ) ) Defendant. )

MEMORANDUM AND ORDER

BEATTY, Magistrate Judge: In accordance with 42 U.S.C. § 405(g), Plaintiff Shardae B. is before the Court, represented by counsel, seeking review of the final decision of the Commissioner of Social Security denying her applications for Disability Insurance Benefits (DIB) and Supplemental Security Income (SSI) under Titles II and XVI of the Social Security Act. For the reasons set forth below, the Commissioner’s decision is REVERSED and this matter is REMANDED for rehearing and reconsideration of the evidence pursuant to sentence four of 42 U.S.C. § 405(g). PROCEDURAL HISTORY Plaintiff protectively filed a Title II application for a period of disability and DIB on January 14, 2021 (Tr. 30, 126-127). Plaintiff also filed a Title XVI application for SSI on

1 In keeping with the Court’s practice, Plaintiff’s full name will not be used in this Memorandum and Order due to privacy concerns. See Fed. R. Civ. P. 5.2(c) and the Advisory Committee Notes thereto. 2 This case was assigned to the undersigned for final disposition upon consent of the parties pursuant to 28 U.S.C. § 636(c) (Doc. 26). that date (Tr. 30, 126-127). Plaintiff’s applications both alleged disability beginning on January 1, 2021, due to physical and mental conditions including multiple sclerosis

(“MS”), dizziness, balance issues, trouble walking, fatigue, and depression (see, e.g. Tr. 262, 305). Plaintiff’s applications were initially denied in August 2021 (Tr. 30, 126-127). They were then denied upon reconsideration in December 2021 (Tr. 30, 164-165). Plaintiff requested a rehearing by an Administrative Law Judge (ALJ) (see Tr. 177-178), which occurred on October 19, 2022 (Tr. 49-100). Following the hearing, ALJ Brian Battles issued

an unfavorable decision dated March 9, 2023 (Tr. 30-42). Thereafter, Plaintiff’s request for review was denied by the Appeal’s Council and thus, the ALJ’s decision became the final agency decision (Tr. 1-6). Accordingly, Plaintiff exhausted her administrative remedies and filed a timely complaint in this Court seeking judicial review of the ALJ’s adverse decision (Doc. 1).

APPLICABLE LEGAL STANDARDS To qualify for DIB or SSI, a claimant must be disabled within the meaning of the applicable statutes and regulations.3 Under the Social Security Act, a person is disabled if she has an “inability to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result

3 The statutes and regulations pertaining to DIB are found at 42 U.S.C. § 423, et seq., and 20 C.F.R. pt. 404. The statutes and regulations pertaining to SSI are found at 42 U.S.C. §§ 1382 and 1382c, et seq., and 20 C.F.R. pt. 416. As is relevant to this case, the DIB and SSI statutes and regulations are identical. Furthermore, 20 C.F.R. § 416.925 detailing medical considerations relevant to an SSI claim, relies on 20 C.F.R. Pt. 404, Subpt. P, of the DIB regulations. Most citations herein are to the DIB regulations out of convenience. in death or which has lasted or can be expected to last for a continuous period of not less than twelve months.” 42 U.S.C. § 423(d)(1)(A).

To determine whether a claimant is disabled, the ALJ conducts a five-step sequential analysis. 20 C.F.R. § 416.920(a)(4). The first step is to determine whether the claimant is presently engaged in substantial gainful activity. Id. at § 416.920(a)(4)(i). If the answer is yes, then the claimant is not disabled regardless of their medical condition, age, education, and work experience. Id. at § 416.920(a)(4)(i), (b). If the answer is no and the individual is not engaged in substantial gainful activity, the analysis proceeds to the

second step. Id. at § 416.920(a)(4). At step two, the ALJ considers whether the claimant has a medically determinable physical or mental impairment, or a combination of impairments, that is “severe” and expected to persist for at least twelve months. 20 C.F.R. § 416.920(a)(4)(ii), 416.909. If the answer is no, then the claimant is not disabled. Id. at § 416.920(c). If the answer is yes, the

analysis proceeds to question three. Id. at § 416.920(a)(4). At step three, the ALJ must determine whether the claimant’s severe impairments, singly or in combination, meet the requirements of any of the “listed impairments” enumerated in the regulations. 20 C.F.R. § 416.920(a)(4)(iii). See also 20 C.F.R. Pt. 404, Subpt. P, Appendix 1 (list of impairments). A claimant who meets the requirements of a

“listed impairment” is deemed disabled. 20 C.F.R. § 416.920(d). For claimants who do not meet the requirements of a “listed impairment,” the ALJ must then determine the claimant’s residual functional capacity (“RFC”). Id. at § 416.920(e). An individual’s RFC is his or her ability do work despite the individual’s impairments. Id. at § 416.945; see also Craft v. Astrue, 539 F.3d 668, 675-76 (7th Cir. 2008)

(“RFC is the maximum that a claimant can still do despite his mental and physical limitations.”). “In assessing a claimant’s RFC, the ALJ must consider all of the relevant evidence in the record and provide a ‘narrative discussion’ that cites to specific evidence and describes how that evidence supports the assessment. The ALJ’s analysis and discussion should be thorough and ‘[s]et forth a logical explanation of the effects of the symptoms, including pain, on the individual’s ability to work.’” Passig v. Colvin, 224 F.

Supp. 3d 672, 680 (S.D. Ill. 2016) (quoting SSR 96-8). At step four, the ALJ must determine whether the claimant retains the RFC to perform the requirements of their past relevant work. 20 C.F.R. § 416.920(a)(4)(iv). If the answer is yes, then the claimant is not disabled. Id. at § 416.920(a)(4)(iv), (f). If the answer is no, the analysis proceeds to the final step. Id. at § 416.920(a)(4).

At the fifth and final step, the ALJ must consider whether the claimant can make an adjustment to perform any other work considering the claimant’s RFC, age, education, and work experience. Id. at § 416.920(a)(4)(v). If the claimant can make an adjustment to other work, then the claimant is not disabled. Id. at § 416.920(g).

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Barnes v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barnes-v-commissioner-of-social-security-ilsd-2025.