Boose v. O'Malley

CourtDistrict Court, N.D. Illinois
DecidedSeptember 18, 2024
Docket3:23-cv-50183
StatusUnknown

This text of Boose v. O'Malley (Boose v. O'Malley) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Boose v. O'Malley, (N.D. Ill. 2024).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS WESTERN DIVISION Romona R. B., ) ) Plaintiff, ) ) Case No. 3:23-cv-50183 v. ) ) Magistrate Judge Margaret J. Schneider Martin O’Malley, ) Commissioner of Social Security, ) ) Defendant. )

MEMORANDUM OPINION AND ORDER Plaintiff Romona R. B. brings this action under 42 U.S.C. § 405(g) seeking a remand of the decision denying her applications for disability insurance benefits and supplemental security income.1 For the reasons set forth below, the Commissioner’s decision is affirmed.

I. Background In July 2021, Plaintiff filed applications for disability insurance benefits and supplemental security income, alleging a disability beginning on April 12, 20192 because of back pain. R. 16; R. 111. Plaintiff was 50 years old on her alleged onset date.

Following a hearing, an administrative law judge (“ALJ”) issued a decision in September 2022, finding that Plaintiff was not disabled. R. 15–27. The ALJ found that Plaintiff had the following severe impairments: degenerative disc disease in the cervical spine with history of discectomy and fusion; degenerative disc disease in the lumbar spine, status-post laminectomy; medial facetectomy and foraminotomies; and asthma. The ALJ determined that Plaintiff’s impairments did not meet or medically equal a listed impairment. The ALJ concluded that Plaintiff had the residual functional capacity (“RFC”) to perform light work with certain restrictions. The ALJ determined that Plaintiff was unable to perform any past relevant work, but that there were

1 The parties have consented to the jurisdiction of a United States Magistrate Judge for all proceedings pursuant to 28 U.S.C. § 636(c). Dkt. 28. 2 Plaintiff amended her alleged onset date from April 9 to April 12, 2019 because she previously received an unfavorable decision on April 11, 2019 finding her not disabled, and she was not seeking to reopen her prior applications. R. 16. other jobs that existed in significant numbers in the national economy that she could perform, namely light, unskilled jobs.

After the Appeals Council denied Plaintiff’s request for review on March 17, 2023, R. 1, Plaintiff filed the instant action. Dkt. 1.

II. Standard of Review The reviewing court evaluates the ALJ’s determination to establish whether it is supported by “substantial evidence,” meaning “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Moore v. Colvin, 743 F.3d 1118, 1120-21 (7th Cir. 2014) (quoting Richardson v. Perales, 402 U.S. 389, 401 (1971)). While substantial evidence is “more than a mere scintilla, . . . the threshold for such evidentiary sufficiency is not high.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (internal quotation marks and citation omitted). The substantial evidence standard is satisfied when the ALJ provides “an explanation for how the evidence leads to their conclusions that is sufficient to allow us, as a reviewing court, to assess the validity of the agency’s ultimate findings and afford [the appellant] meaningful judicial review.” Warnell v. O’Malley, 97 F.4th 1050, 1052 (7th Cir. 2024) (internal quotation marks and citation omitted). An ALJ “need not specifically address every piece of evidence but must provide a logical bridge between the evidence and [the] conclusions.” Bakke v. Kijakazi, 62 F.4th 1061, 1066 (7th Cir. 2023) (internal quotation marks and citation omitted); see also Warnell, 97 F.4th at 1054.

The court will only reverse the decision of the ALJ “if the record compels a contrary result.” Gedatus v. Saul, 994 F.3d 893, 900 (7th Cir. 2021) (internal quotation marks and citation omitted). The court is obligated to “review the entire record, but [the court does] not replace the ALJ’s judgment with [its] own by reconsidering facts, reweighing or resolving conflicts in the evidence, or deciding questions of credibility. . . . [The court’s] review is limited also to the ALJ’s rationales; [the court does] not uphold an ALJ’s decision by giving it different ground to stand upon.” Jeske v. Saul, 955 F.3d 583, 587 (7th Cir. 2020).

III. Discussion Plaintiff argues that a remand is appropriate because: (1) the ALJ’s assessment of Plaintiff’s RFC was not supported by substantial evidence and violated Social Security Ruling 96-8p; and (2) the ALJ’s evaluation of Plaintiff’s subjective symptoms was not supported by substantial evidence and violated Social Security Ruling 16-3p.

A. RFC Plaintiff argues that the ALJ failed to articulate the reasoning behind his RFC determinations as required by Social Security Ruling 96-8p. Specifically, Plaintiff argues that the ALJ: (1) arbitrarily and independently came up with the four-hour stand and/or walk limitation; (2) failed to include Plaintiff’s need to use a cane; (3) improperly relied on evidence noting Plaintiff’s occasional exercise; and (4) should have been “specific as to the frequency of [Plaintiff’s] need to alternate sitting and standing.” Pl.’s Br. at 8, Dkt. 15. Accordingly, Plaintiff argues that a remand is required because “the ALJ’s decision lacks the required analysis or the narrative statement on how he arrived at his [RFC] conclusions.” Id. at 10.

Before addressing each of Plaintiff’s arguments, this Court notes at the outset that Plaintiff’s arguments in support of remand are generally conclusory and rely largely on Plaintiff’s subjective complaints, which the ALJ discounted as inconsistent with the evidence in the record. Plaintiff takes issue with the ALJ’s RFC determination, but the record reveals no medical source that opined to limitations greater than those adopted by the ALJ. This is critical because the Seventh Circuit has stated that “when no doctor’s opinion indicates greater limitations than those found by the ALJ, there is no error.” Dudley v. Berryhill, 773 F. App’x 838, 843 (7th Cir. 2019) (unpublished) (citing Rice v. Barnhart, 384 F.3d 363, 370 (7th Cir. 2004)); Gedatus, 994 F.3d at 904 (finding the fact that no doctor offered any opinion setting sitting limits greater than those set by the ALJ a “fundamental problem”); see also Hosea M. v. Saul, No. 18 CV 2926, 2019 WL 5682835, at *7 (N.D. Ill. Nov. 1, 2019) (“[C]ourts within this Circuit have repeatedly held that ‘[t]here is no error’ in the formulation of an RFC ‘when there is no doctor’s opinion contained in the record [that] indicates greater limitations than those found by the ALJ.’”) (collecting cases). For the reasons discussed below, Plaintiff’s arguments do not warrant a remand.

A claimant’s RFC is the maximum work she can perform despite any limitations. 20 C.F.R. § 404.1545(a)(1); Social Security Ruling 96-8p, 1996 WL 374184, at *2. An ALJ must base a claimant’s RFC on all relevant evidence in the record, including the claimant’s medical history, medical findings and opinions, reports of daily activities, and the effects of the claimant’s symptoms and treatment. 20 C.F.R. § 404

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Bluebook (online)
Boose v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/boose-v-omalley-ilnd-2024.