BROWN v. O'MALLEY

District Court, S.D. Indiana·Decided August 27, 2024·No. 1:23-cv-01773·Unknown

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

AARON B.,1 ) ) Plaintiff, ) ) v. ) No. 1:23-cv-01773-RLY-KMB ) MARTIN J. O'MALLEY, Commissioner of ) Social Security Administration, ) ) Defendant. ) ENTRY ADOPTING REPORT AND RECOMMENDATION Plaintiff Aaron B. suffers from a variety of ailments, including heart failure and cardiomegaly. He applied for disability insurance benefits on April 1, 2021, alleging an onset date of July 1, 2019. (Filing No. 7-5 at 2). His claim was denied initially on August 17, 2021, and upon reconsideration on February 10, 2022. (Filing No. 7-4 at 9, 16). An Administrative Law Judge ("ALJ") held a hearing on December 13, 2022. (Filing No. 7-2, ALJ Decision at 18). The ALJ issued an unfavorable decision on February 9, 2023, concluding that Plaintiff was not disabled. (Id. at 18, 27). The Appeals Council denied Plaintiff's request for review, making the ALJ's decision the final decision of the Commissioner of Social Security. (Id. at 2).

1 To protect the privacy interest 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. On October 2, 2023, Plaintiff filed a request for judicial review of the decision denying him benefits. (Filing No. 1.). The court referred the matter to Magistrate Judge Barr on March 21, 2024, pursuant to 28 U.S.C. § 636. (Filing No. 12). In a thorough

opinion, the Magistrate Judge recommended that the court affirm the Commissioner's decision. (Filing No. 14). Plaintiff objects to the Magistrate Judge's recommendation. (Filing No. 15). For the reasons set forth below, the court OVERRULES Plaintiff's Objection and ADOPTS the Magistrate Judge's Report and Recommendation. I. Background

The ALJ analyzed Plaintiff's claim in accordance with the five-step sequential evaluation process for determining disability set forth in 20 C.F.R. § 404.1520(a)(4) and concluded Plaintiff was not disabled. (See ALJ Decision at 18–27). At step one, the ALJ found that Plaintiff had not engaged in substantial gainful activity since July 1, 2019. (Id. at 20). At step two, the ALJ found Plaintiff had the severe impairments of heart failure

and cardiomegaly. (Id.). The ALJ also found he had the non-severe impairments of obesity, diabetes and hypertension, obstructive sleep apnea, chronic kidney disease, umbilical hernia, and marijuana abuse. (Id.). At step three, the ALJ found Plaintiff did not have an impairment or combination of impairments meeting or medically equaling the severity of one of the listed impairments. (Id. at 21). Finally, the ALJ concluded

Plaintiff could not perform any of his past work (step four) but that there were jobs existing in significant numbers in the national economy that he could perform (step five). (Id. at 24–26). Before step four, the ALJ determined Plaintiff had the residual functional capacity ("RFC") to perform "light work" with the following limitations: [N]ever climb ladders, ropes, or scaffolds; occasionally climb ramps and stairs, balance, stoop, kneel, crouch, and crawl; no more than occasional exposure to wetness and industrial vibrations; avoid all use of hazardous machinery and exposure to unprotected heights; and no job where driving or operating motorized vehicles is required to perform functions of the job.

(Id. at 21).

In her Report and Recommendation, the Magistrate Judge concluded that the ALJ's subjective symptom analysis was not patently wrong and thus did not warrant reversal. Additionally, the Magistrate Judge concluded that the ALJ did not commit substantial error when she did not incorporate leg elevation requirements into Plaintiff's RFC. Plaintiff objects, arguing the ALJ committed reversible error in her subjective symptom analysis. II. Standard of Review The court reviews de novo the portions of the Magistrate Judge's Report and Recommendation to which objections have been filed. Fed. R. Civ. P. 72(b)(3). The court "may accept, reject, or modify the recommended disposition." Id. The ALJ's decision will be upheld "so long as it uses the correct legal standards and . . . is supported by substantial evidence." Roddy v. Astrue, 705 F.3d 631, 636 (7th Cir. 2013). Substantial evidence is "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion." Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (quoting Consol. Edison Co. of N.Y. v. N.L.R.B., 305 U.S. 197, 229 (1938)). "The ALJ is not required to mention every piece of evidence but must provide an 'accurate and logical bridge' between the evidence and the conclusion that the claimant is not disabled" so that the court "may assess the validity of the agency's ultimate findings and afford [the] claimant meaningful judicial review." Craft v. Astrue, 539 F.3d 668, 673 (7th Cir. 2008) (emphasis

in original) (quoting Young v. Barnhart, 362 F.3d 995, 1002 (7th Cir. 2004)). Courts defer to an ALJ's determinations of credibility unless "patently wrong." Zoch v. Saul, 981 F.3d 597, 601 (7th Cir. 2020) (quoting Summers v. Berryhill, 864 F.3d 523, 528 (7th Cir. 2017)). III. Discussion

Plaintiff objects to the Magistrate Judge's Report and Recommendation on two grounds: (1) the ALJ erroneously equated Plaintiff's activities of daily living to the ability to perform full-time work without adequately considering the limitations on his ability to complete those activities, and (2) the ALJ improperly relied on improvement in his condition in determining that his symptoms were less severe than he maintained.

Having reviewed the record, the court agrees with the Magistrate Judge that the ALJ did not improperly equate Plaintiff's ability to complete daily living activities with the ability to perform full-time work. While ALJs must be careful not to equate daily activities "with the rigorous demands" of full-time work, "it is entirely permissible to examine all of the evidence, including a claimant's daily activities, to assess whether

testimony about the effects of his impairments was credible or exaggerated." Prill v. Kijakazi, 23 F.4th 738, 748 (7th Cir. 2022) (quoting Alvarado v. Colvin, 836 F.3d 744, 750 (7th Cir. 2016)). The ALJ noted that Plaintiff "cooks for his family, has no problems with personal care, does laundry, mows the grass, drives a car, goes out alone, shops in stores, handles his finances, and is generally able to function independently and take care of his own basic needs." (ALJ Decision at 23).

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