Craig v. SSA

CourtDistrict Court, E.D. Kentucky
DecidedMay 13, 2025
Docket5:24-cv-00332
StatusUnknown

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

Bluebook
Craig v. SSA, (E.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION LEXINGTON R.C., ) ) Plaintiff, ) Civil No. 5:24-cv-00332-GFVT ) v. ) MEMORANDUM OPINION

) & LELAND DUDEK, Acting Commissioner of ) ORDER Social Security, )

) Defendant. ) *** *** *** *** Plaintiff R.C. seeks judicial review of an administrative decision denying his claim for supplemental security income.1 R.C. brings this action pursuant to 42 U.S.C. § 405(g), alleging error on the part of the administrative law judge who considered the matter. The Court, having reviewed the record and for the reasons set forth herein, will DENY R.C’s Motion for Summary Judgment [R. 7] and GRANT the Commissioner’s [R. 9]. I Plaintiff R.C. filed an application for supplemental security income (SSI) on April 20, 2022. [R. 6 at 173.] Since SSI is not payable for any months prior to the application filing date, the relevant period started in April 2022. See 20 C.F.R. §§ 416.330, 416.335. The Social Security Administration denied his claim on its initial review. [R. 6 at 53.] On reconsideration, the Social Security Administration again denied R.C’s claim. Id. at 60. R.C. then had a hearing before Administrative Law Judge Davida Isaacs, who again denied R.C.’s request for benefits. Id. at 19. On September 12, 2024, the Appeals Council denied review, leading R.C. to file a

1 The claimant’s initials are used in lieu of their name to protect their sensitive medical information contained throughout the Memorandum Opinion and Order. Complaint with this Court, seeking review under 42 U.S.C. § 405(g). [R. 1.] Both parties have now filed motions for summary judgment which are ripe for review. [R. 7; R. 9.] II To evaluate a claim of disability for Supplemental Security Income disability benefits,

the ALJ conducts a five-step analysis. See 20 C.F.R. § 416.920. If at any step the ALJ can find that the claimant is disabled or not disabled, the analysis stops. Id. § 404.1520(a)(4). First, if a claimant is performing substantial gainful activity, he is not disabled. Id. § 404.1520(a)(4)(i). Second, if a claimant does not have a severe impairment or combination of impairments, he is not disabled. Id. § 404.1520(ii). Third, if a claimant’s impairments meet or equal one of the impairments listed in 20 C.F.R. Part 404, Subpart P, Appendix 1, he is disabled. Id. §§ 404.1520(a)(4)(iii), (d). Before moving on to the fourth step, the ALJ must use all the relevant evidence in the record to determine the claimant’s residual functional capacity, which assesses his ability to perform certain physical and mental work activities on a sustained basis despite any impairment.

See id. C.F.R. §§ 404.1520(e), 404.1545. Under the fourth step, an ALJ uses a claimant’s RFC to determine whether he is still able to do her past work. Id. § 404.1520(a)(4)(iv). If so, he is not disabled. Id. Finally, if an ALJ assesses a claimant’s RFC in conjunction with his age, education, and work experience and finds that the claimant cannot adjust to perform other jobs available in significant numbers in the national economy, the claimant is disabled. See Id. §§ 404.1520(g), 404.1560(c). Through step four of the analysis, “the claimant bears the burden of proving the existence and severity of limitations caused by [his] impairments and the fact that [he] is precluded from performing [his] past relevant work.” Jones v. Comm’r of Soc. Sec., 336 F.3d 469, 474 (6th Cir. 2003). A The ALJ completed the first two steps of the five-step analysis to determine R.C.’s disability status. She first determined that R.C. had not engaged in substantial gainful

employment during the period in which he claimed to be disabled. [R. 6 at 25.] Then, the ALJ found that R.C. “does not have an impairment or combination of impairments that has significantly limited (or is expected to significantly limit) the ability to perform basic work- related activities for 12 consecutive months” and therefore “does not have a severe impairment or combination of impairments.” Id. at 25. The ALJ found R.C. to have the following medically determinable impairments: substance (heroin) abuse, in remission; degenerative joint disease of the knees; sinus bradycardia; preliminary HIV positive; and residual effects of remote Hepatitis C infection. Id. Nevertheless, the ALJ found R.C.’s degenerative disc disease of the lumbar spine to be “not medically determinable.” Id. The ALJ then walked through the available

medical evidence, considering R.C.’s claimed symptoms, R.C.’s own testimony, R.C.’s medical records, the opinion of healthcare providers, and the opinion of state agency examiners. Id. at 25-29. Based on that evidence, the ALJ made an unfavorable severity determination and found that R.C. is not disabled. Id. B The Court’s review of the ALJ’s determination is limited to whether there is substantial evidence in the record to support the ALJ’s decision. 42 U.S.C. § 405(g); Wright v. Massanari, 321 F.3d 611, 614 (6th Cir. 2003). “Substantial evidence” is said to be “more than a scintilla of evidence but less than a preponderance; it is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Cutlip v. Sec’y of Health & Human Servs., 25 F.3d 284, 286 (6th Cir. 1994) (citing Richardson v. Perales, 402 U.S. 389, 401 (1971)). The substantial evidence standard “presupposes that there is a zone of choice within which [administrative] decision makers can go either way, without interference by the courts.” Mullen

v. Bowen, 800 F.2d 535, 545 (6th Cir. 1986) (quoting Baker v. Heckler, 730 F.2d 1147, 1150 (8th Cir. 1984)). To decide whether substantial evidence exists, courts must examine the record as a whole. Cutlip, 25 F.3d at 286 (citing Kirk v. Sec’y of Health & Human Servs., 667 F.2d 524, 535 (6th Cir. 1981), cert. denied, 461 U.S. 957 (1983)). A reviewing court is restricted from making factual findings de novo, resolving conflicts in the evidence, or making credibility determinations. Ulman v. Comm’r of Soc. Sec., 693 F.3d 709, 713 (6th Cir. 2012). Rather, if the Commissioner’s decision is supported by substantial, legitimate evidence, it must be affirmed even if the reviewing court would decide the matter differently, and even if substantial evidence also supports the opposite conclusion. Id. at 714.

R.C. raises two issues with how the ALJ decided his case. First, he argues that the ALJ erred in finding he did not have a severe impairment. [R.

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