Cramer v. Commissioner of Social Security

CourtDistrict Court, N.D. Indiana
DecidedAugust 8, 2025
Docket3:24-cv-00682
StatusUnknown

This text of Cramer v. Commissioner of Social Security (Cramer 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
Cramer v. Commissioner of Social Security, (N.D. Ind. 2025).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

CHRISTOPHER N. CRAMER, ) ) Plaintiff, ) ) v. ) CAUSE NO. 3:24-cv-00682-ALT ) COMMISSIONER OF SOCIAL ) SECURITY, sued as Frank Bisignano,1 ) Commissioner of Social Security, ) ) Defendant. )

OPINION AND ORDER

Plaintiff Christopher N. Cramer appeals to the district court from a final decision of the Commissioner of Social Security (“Commissioner”) denying his application under the Social Security Act (the “Act”) for Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”). (ECF 1). For the following reasons, the Commissioner’s decision will be AFFIRMED. I. FACTUAL AND PROCEDURAL HISTORY Cramer applied for DIB and SSI in February 2021, alleging disability as of January 15, 2020. (ECF 10 Administrative Record (“AR”) 22, 253-60).2 Cramer’s claim was denied initially and upon reconsideration. (AR 22, 119-37, 141-55). On March 17, 2022, administrative law judge (“ALJ”) Stephanie Katich conducted an administrative hearing (AR 44-84), and on June 8,

1 Frank Bisignano became the Commissioner of Social Security in May 2025, and thus, pursuant to Federal Rule of Civil Procedure 25(d), he is automatically substituted for his predecessor as the defendant in this suit. See La’Toya R. v. Bisignano, No. 1:24-cv-01564-JMS-TAB, 2025 WL 1413807, at *n.2 (S.D. Ind. May 15, 2025).

2 The AR page numbers cited herein correspond to the ECF-generated page numbers displayed at the top center of the screen when the AR is open in ECF, rather than the page numbers printed in the lower right corner of each page. 2022, rendered an unfavorable decision to Cramer, concluding that he was not disabled because he could perform a significant number of unskilled, light-exertional jobs in the national economy despite the limitations caused by his impairments (AR 22-37). The Appeals Council denied Cramer’s request for review (AR 8), and Cramer filed a complaint in this Court appealing the Commissioner’s final decision. See Cramer v. Comm’r of Soc. Sec., No. 3:22-cv-00980-MGG

(N.D. Ind. filed Nov. 21, 2022). In June 2023, pursuant to an agreed motion by the parties, the Court remanded that case to the Commissioner. (AR 1895-98). On remand, Cramer’s initial application was consolidated with his subsequent application filed in November 2022. (AR 1904). On February 7, 2024, the ALJ conducted another administrative hearing (AR 1801-47), and on April 17, 2024, rendered another unfavorable decision to Cramer, again concluding that he was not disabled because he could perform a significant number of unskilled, light-exertional jobs in the national economy despite the limitations caused by his impairments (AR 1773-91). After Cramer failed to file timely exceptions with the Appeals Council (AR 1761), the ALJ’s decision became the final

decision of the Commissioner. See 20 C.F.R. §§ 404.981, 416.1481. On August 14, 2024, Cramer filed another complaint in this Court appealing the Commissioner’s final decision. (ECF 1). Cramer advances just one argument in his opening brief—that the ALJ improperly assessed the severity and functional impact of Cramer’s right wrist disorder. (ECF 17 at 5). On the date of the Commissioner’s final decision, Cramer was thirty-two years old (AR 253, 1791); was a high school graduate (AR 1806); and had past relevant work as an equipment cleaner, hand polisher, and fast-food cook (AR 1789). At the hearing, Cramer testified that he was currently working twelve hours a week at a grocery store. (AR 1776, 1809). In his application, Cramer alleged that he is disabled due to the following conditions: epilepsy, daily violent seizures, torn ligaments, right hand injury, torn right meniscus, allergies, tendinitis, and severe abdominal pain. (AR 273). II. STANDARD OF REVIEW Section 405(g) of the Act grants this Court the “power to enter, upon the pleadings and transcript of the record, a judgment affirming, modifying, or reversing the decision of the

Commissioner . . . , with or without remanding the cause for a rehearing.” 42 U.S.C. § 405(g). The Court’s task is limited to determining whether the ALJ’s factual findings are supported by substantial evidence, which means “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Schmidt v. Barnhart, 395 F.3d 737, 744 (7th Cir. 2005) (citation omitted). The decision will be reversed “only if [it is] not supported by substantial evidence or if the Commissioner applied an erroneous legal standard.” Clifford v. Apfel, 227 F.3d 863, 869 (7th Cir. 2000) (citation omitted). To determine if substantial evidence exists, the Court “review[s] the entire administrative record, but do[es] not reweigh the evidence, resolve conflicts, decide questions of credibility, or

substitute [its] own judgment for that of the Commissioner.” Id. (collecting cases). “Rather, if the findings of the Commissioner . . . are supported by substantial evidence, they are conclusive.” Jens v. Barnhart, 347 F.3d 209, 212 (7th Cir. 2003) (citation omitted). “In other words, so long as, in light of all the evidence, reasonable minds could differ concerning whether [the claimant] is disabled, we must affirm the ALJ’s decision denying benefits.” Books v. Chater, 91 F.3d 972, 978 (7th Cir. 1996). III. ANALYSIS A. The Law Under the Act, a claimant seeking DIB or SSI must establish that he is “unable to engage in any substantial gainful activity by reason of any medically determinable physical or mental impairment . . . which has lasted or can be expected to last for a continuous period of not less than twelve months.” 42 U.S.C. § 1382c(a)(3)(A); see also id. §§ 416(i)(1), 423(d)(1)(A). A physical or mental impairment is “an impairment that results from anatomical, physiological, or psychological abnormalities which are demonstrable by medically acceptable clinical and

laboratory diagnostic techniques.” Id. §§ 423(d)(3), 1382c(a)(3)(D). The Commissioner evaluates disability claims pursuant to a five-step evaluation process, requiring consideration of the following issues, in sequence: (1) whether the claimant is currently unemployed in substantial gainful activity, (2) whether he has a severe impairment, (3) whether his impairment is one that the Commissioner considers conclusively disabling, (4) whether he is incapable of performing his past relevant work, and (5) whether he is incapable of performing any work in the national economy. See Dixon v. Massanari, 270 F.3d 1171, 1176 (7th Cir. 2001); see also 20 C.F.R. §§ 404.1520, 416.920.3 “[A]n affirmative answer leads either to the next step, or, on Steps 3 and 5, to a finding that the claimant is disabled. A negative answer at any point,

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