Crosby v. O'Malley

CourtDistrict Court, N.D. Illinois
DecidedJanuary 31, 2025
Docket1:22-cv-02444
StatusUnknown

This text of Crosby v. O'Malley (Crosby 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
Crosby v. O'Malley, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

MARSHELLE C.,1 ) ) Plaintiff, ) ) No. 22 C 2444 v. ) ) Magistrate Judge Laura K. McNally MICHELLE A. KING, ) Acting Commissioner of ) Social Security,2 ) ) Defendant. )

ORDER3

Before the Court is Plaintiff Marshelle C.’s motion in support of summary judgment, asking the Court to remand the Administrative Law Judge’s (“ALJ”) decision denying her applications for disability benefits (Dkt. 11: Pl. Mem. in Support of Summ. J., “Pl. Mem.”) and Defendant’s motion and brief in support of summary judgment (Dkt. 12: Def. Mot. for Summ. J.; Dkt. 13: Def. Mem. in Support of Summ. J.: “Resp.”).

1 The Court in this order is referring to Plaintiff by her first name and first initial of her last name in compliance with Internal Operating Procedure No. 22 of this Court.

2 The Court substitutes Michelle A. King for her predecessor, Carolyn Colvin, as the proper defendant in this action pursuant to Federal Rule of Civil Procedure 25(d) (a public officer’s successor is automatically substituted as a party).

3 On May 17, 2022, by consent of the parties and pursuant to 28 U.S.C. § 636(c) and Local Rule 73.1, this case was reassigned to the magistrate judge for all proceedings, including entry of final judgment. (Dkt. 8.) I. Procedural History Plaintiff applied for disability insurance benefits (“DIB”) on January 21, 2020 and

for supplemental security income (“SSI”) on January 23, 2020, alleging disability for both claims beginning May 1, 2017. (R. 247-54.) Her date last insured was December 31, 2022 (R. 18.) The ALJ held a hearing on August 3, 2021, at which Plaintiff (who was

represented by counsel), Plaintiff’s friend, and a vocational expert testified. (R. 16.) On September 3, 2021, the ALJ issued a decision finding Plaintiff not disabled, and she subsequently appealed.4 After considering the parties’ briefs and evidence, the Court

denies Plaintiff’s motion for summary judgment and grants the Commissioner’s motion. II. ALJ Decision The ALJ applied the Social Security Administration’s (“SSA”) five-step

sequential evaluation process to Plaintiff’s claims. At Step One, the ALJ found that the Plaintiff had not engaged in substantial gainful activity since her alleged onset date (R. 18.) At Step Two, the ALJ determined that Plaintiff had the following severe

impairments: lumbar degenerative disc disease, osteoarthritis, and chronic regional pain syndrome (CRPS) in the lower right extremity. (R. 19.) She determined that Plaintiff’s hypertension, GERD, pre-diabetes, hyperlipidemia, asthma, and muscle

4 The Appeals Council subsequently denied review of the second opinion (R. 1), making the ALJ’s decision the final decision of the Commissioner. Bertaud v. O’Malley, 88 F.4th 1242, 1244 (7th Cir. 2023). strain of the right thigh were nonsevere and that her symptoms did not significantly limit her mental or physical ability to perform work-related activities. (Id.) Moreover,

the ALJ determined that Plaintiff’s obesity did not support more than minimal limitations on her ability to work because there were “no significant objective medical findings in the record.” (R. 19.)

At Step Three, the ALJ found that none of Plaintiff’s impairments met a Listing. (R. 21.) Before Step Four, the ALJ determined that Plaintiff had a residual functional capacity for sedentary work except she can “occasionally climb ramps and stairs; can

never climb ladders, ropes or scaffolds; can occasionally stoop, kneel, crouch, and crawl; must avoid concentrated exposure to temperature extremes and dampness; can occasionally use the right lower extremity for foot controls; and on some days, may need a cane for ambulation.” (R. 22)

At Step Four the ALJ found Plaintiff was unable to perform her previous work but found at Step Five that there were significant jobs in the national economy Plaintiff could perform. (R. 28.) Therefore, the ALJ held that Plaintiff was not disabled. (R. 29.)

III. Legal Standard Under the Act, a person is disabled if she has an “inability 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 twelve months.” 42 U.S.C. § 423(d)(1)(a).

The Court does not “merely rubber stamp the ALJ's decision on judicial review.” Prill v. Kijakazi, 23 F.4th 738, 746 (7th Cir. 2022) An ALJ’s decision will be affirmed if it is supported by “substantial evidence,” which means “such relevant evidence as a

reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019). “[T]he threshold for such evidentiary sufficiency is not high.” Id. ALJs are “subject to only the most minimal of articulation requirements” and “need

not address every piece or category of evidence identified by a claimant, fully summarize the record, or cite support for every proposition or chain of reasoning.” Warnell v. O’Malley, 97 F.4th 1050, 1053 (7th Cir. 2024). “All we require is that ALJs provide 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.” Id. at 1054. The Seventh Circuit added that “[a]t times, we have put this in the shorthand

terms of saying an ALJ needs to provide a ‘logical bridge from the evidence to his conclusion.’” Id. (citation omitted). The Seventh Circuit further has clarified that district courts, on review of ALJ decisions in Social Security appeals, are subject to a similar minimal articulation requirement: “A district (or magistrate) judge need only

supply the parties . . . with enough information to follow the material reasoning underpinning a decision.” Morales v. O’Malley, 103 F.4th 469, 471 (7th Cir. 2024). The district court’s review of the ALJ’s opinion “will not reweigh the evidence, resolve

debatable evidentiary conflicts, determine credibility, or substitute its judgment for the ALJ’s determination.” Chavez v. O’Malley, 96 F.4th 1016, 1021 (7th Cir. 2024) (internal quotations omitted).

IV. Analysis Plaintiff makes three arguments for remand: (1) The ALJ’s subjective symptom evaluation was patently wrong; (2) The ALJ erred in finding her treating doctor’s

opinion not persuasive; and (3) The ALJ did not support her residual functional capacity evaluation with substantial evidence; (Pl. Mem. at 2.) For the reasons that follow, the Court concludes that the ALJ did not err and Plaintiff’s motion must be denied.

A. The ALJ’s Subjective Symptom Analysis was not Patently Wrong. Plaintiff argues that in evaluating the severity of her subjective symptoms, the ALJ (1) failed to properly assess her activities of daily living; (2) failed to acknowledge

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Crosby v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/crosby-v-omalley-ilnd-2025.