Bishop v. Commissioner of Social Security

CourtDistrict Court, N.D. Indiana
DecidedMarch 31, 2025
Docket3:24-cv-00271
StatusUnknown

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

Bluebook
Bishop v. Commissioner of Social Security, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

DEBRA JEAN BISHOP,

Plaintiff,

v. Case No. 3:24-CV-271 JD

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

OPINION AND ORDER Plaintiff Debra Bishop appeals the denial of her claims for disability insurance benefits under Title II of the Social Security Act. For the reasons below, the Court will affirm the Commissioner’s decision.

A. Background Ms. Bishop applied to the Social Security Administration for disability benefits, alleging that she became disabled in January 2022. She was then 58 years old. Ms. Bishop claimed disability based on her left arm pain, knee replacement, high blood pressure, and back pain. (R. at 79, 88.) Ms. Bishop’s claims were rejected, leading to a review by an Administrative Law Judge (“ALJ”). In the proceedings before the ALJ, Ms. Bishop maintained that she sustained a shoulder injury in late 2021, resulting in pain and reduced mobility, diagnosed as adhesive capsulitis and a partial supraspinatus tear. Despite steroid injections and physical therapy, she continues to experience discomfort. Her right knee was replaced in 2020, and she now suffers from osteoarthritis in her left knee, managed with medication and injections. Additionally, she has plantar fasciitis and carpal tunnel syndrome, for which she uses pain medication and wrist splints. A consultative exam in May 2022 revealed ongoing pain and stiffness in her left shoulder, right knee, and back, with difficulty moving her left arm and walking. The exam showed a BMI of 37.3 and limited ability to ambulate effectively.

The ALJ issued a decision finding that Ms. Bishop was not disabled. (R. at 34.) In doing so, the ALJ employed the customary five-step analysis. At Step 2, the ALJ determined that Ms. Bishop suffered from the following severe impairments: “left shoulder adhesive capsulitis/small tear; left knee internal derangement; history of right knee arthroplasty; and obesity.” (R. at 27.) On the other hand, the ALJ ruled that Ms. Bishop’s right foot plantar fasciitis and carpal tunnel syndrome (“CTS”) were non-severe impairments. (Id.) At Step 4, the ALJ determined Ms. Bishop’s residual functional capacity (“RFC”), finding that she can perform sedentary work1 . . . except no climbing ladders, ropes, and scaffolds; occasionally climb ramps and stairs, stoop, kneel, crouch, crawl, and balance; occasionally reach overhead with non-dominant left upper extremity; and frequently handle and finger bilaterally. (R. at 28.) In light of this RFC, the ALJ determined that Ms. Bishop is capable of performing past relevant work as a collection clerk. (R. at 34.) The ALJ arrived at this conclusion after questioning a Vocational Expert at the hearing. After the Appeals Council denied Ms. Bishop’s request for review of the ALJ’s decision, she appealed to this Court.

1 “Sedentary work involves lifting no more than 10 pounds at a time and occasionally lifting or carrying articles like docket files, ledgers, and small tools. Although a sedentary job is defined as one which involves sitting, a certain amount of walking and standing is often necessary in carrying out job duties. Jobs are sedentary if walking and standing are required occasionally and other sedentary criteria are met.” 20 C.F.R. § 404.1567. B. Standard of Review Because the Appeals Council denied review, the Court evaluates the ALJ’s decision as the final word of the Commissioner of Social Security. Schomas v. Colvin, 732 F.3d 702, 707

(7th Cir. 2013). This Court will affirm the Commissioner’s findings of fact and denial of benefits if they are supported by substantial evidence. Craft v. Astrue, 539 F.3d 668, 673 (7th Cir. 2008). Substantial evidence consists of “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971). “The threshold for substantial evidence ‘is not high.’” Warnell v. O’Malley, 97 F.4th 1050, 1052 (7th Cir. 2024) (quoting Biestek v. Berryhill, 139 S.Ct. 1148, 1154 (2019)). This evidence must be “more than a scintilla but may be less than a preponderance.” Skinner v. Astrue, 478 F.3d 836, 841 (7th Cir. 2007). Even if “reasonable minds could differ” about the disability status of the claimant, the Court must affirm the Commissioner’s decision as long as it is adequately supported. Elder v. Astrue, 529 F.3d 408, 413 (7th Cir. 2008).

The ALJ has the duty to weigh the evidence, resolve material conflicts, make independent findings of fact, and dispose of the case accordingly. Perales, 402 U.S. at 399–400. In evaluating the ALJ’s decision, the Court considers the entire administrative record but does not reweigh evidence, resolve conflicts, decide questions of credibility, or substitute the Court’s own judgment for that of the Commissioner. Lopez ex rel. Lopez v. Barnhart, 336 F.3d 535, 539 (7th Cir. 2003). Nevertheless, the Court conducts a “critical review of the evidence” before affirming the Commissioner’s decision. Id. An ALJ must evaluate both the evidence favoring the claimant as well as the evidence favoring the claim’s rejection and may not ignore an entire line of evidence that is contrary to his or her findings. Zurawski v. Halter, 245 F.3d 881, 887 (7th Cir. 2001). The ALJ must provide a “logical bridge” between the evidence and the conclusions. Terry v. Astrue, 580 F.3d 471, 475 (7th Cir. 2009).

C. Standard for Disability

Disability benefits are available only to those individuals who can establish disability under the terms of the Social Security Act. Estok v. Apfel, 152 F.3d 636, 638 (7th Cir. 1998). Specifically, the claimant must be unable “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 12 months.” 42 U.S.C. § 423(d)(1)(A). The Social Security regulations create a five-step process to determine whether the claimant qualifies as disabled. 20 C.F.R. §§ 404.1520(a)(4)(i)–(v); 416.920(a)(4)(i)–(v). The steps are to be used in the following order: 1. Whether the claimant is currently engaged in substantial gainful activity; 2. Whether the claimant has a medically severe impairment;

3. Whether the claimant’s impairment meets or equals one listed in the regulations; 4. Whether the claimant can still perform past relevant work; and 5. Whether the claimant can perform other work in the national economy. See Dixon v. Massanari, 270 F.3d 1171, 1176 (7th Cir. 2001). At step two, an impairment is severe if it significantly limits a claimant’s ability to do basic work activities. 20 C.F.R.

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Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
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James Young v. Jo Anne B. Barnhart
362 F.3d 995 (Seventh Circuit, 2004)
Steven Arnold v. Jo Anne B. Barnhart
473 F.3d 816 (Seventh Circuit, 2007)
Roberta Skinner v. Michael J. Astrue, Commissioner
478 F.3d 836 (Seventh Circuit, 2007)
Terry v. Astrue
580 F.3d 471 (Seventh Circuit, 2009)
Getch v. Astrue
539 F.3d 473 (Seventh Circuit, 2008)
Craft v. Astrue
539 F.3d 668 (Seventh Circuit, 2008)

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Bishop v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bishop-v-commissioner-of-social-security-innd-2025.