Davis v. Commissioner of Social Security

CourtDistrict Court, N.D. Indiana
DecidedMarch 2, 2022
Docket1:20-cv-00321
StatusUnknown

This text of Davis v. Commissioner of Social Security (Davis 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
Davis v. Commissioner of Social Security, (N.D. Ind. 2022).

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA FORT WAYNE DIVISION

MARIAH D., ) Plaintiff, ) ) v. ) CAUSE NO.: 1:20-CV-321-JVB ) KILOLO KIJAKAZI, Acting Commissioner ) of the Social Security Administration, ) Defendant. )

OPINION AND ORDER Plaintiff Mariah D. seeks judicial review of the Social Security Commissioner’s decision denying her applications for child disability benefits and supplemental security income and asks this Court to reverse that decision and remand this matter to the agency for further administrative proceedings. For the reasons below, this Court grants Plaintiff’s request, reverses the Administrative Law Judge’s decision, and remands this matter for further administrative proceedings. PROCEDURAL BACKGROUND In Plaintiff’s July 27, 2017 and August 15, 2017 applications for benefits, she alleged that she became disabled on April 6, 2007. After a July 30, 2019 hearing, the Administrative Law Judge (ALJ) issued her decision on August 29, 2019, and found that Plaintiff suffered from the severe impairment of intellectual disorder and the non-severe impairments of scoliosis and asthma. (AR 18). The ALJ determined that Plaintiff did not meet or medically equal a listed impairment in 20 C.F.R. Part 404, Subpart P, Appendix 1 and further determined that Plaintiff had the residual functional capacity [RFC] to perform light work . . . except the claimant is limited to work that can be learned in 30 days, with simple routine tasks, simple work related decisions, and routine workplace changes. (AR 21). The ALJ found that, in light of Plaintiff’s RFC, Plaintiff was able to perform the representative occupations of hand packager, mail sorter, and housekeeper. (AR 27). Accordingly, the ALJ found Plaintiff to be not disabled from April 6, 2007, through August 29, 2019, which is the date of the ALJ’s decision. This decision became final when the Appeals Council denied Plaintiff’s request for review.

STANDARD OF REVIEW This Court has authority to review the Commissioner’s decision under 42 U.S.C. § 405(g). The Court will ensure that the ALJ built an “accurate and logical bridge” from evidence to conclusion. Thomas v. Colvin, 745 F.3d 802, 806 (7th Cir. 2014). This requires the ALJ to “confront the [plaintiff’s] evidence” and “explain why it was rejected.” Thomas v. Colvin, 826 F.3d 953, 961 (7th Cir. 2016). The Court will uphold decisions that apply the correct legal standard and are supported by substantial evidence. Briscoe ex rel. Taylor v. Barnhart, 425 F.3d 345, 351 (7th Cir. 2005). Evidence is substantial if “a reasonable mind might accept [it] as adequate to support [the ALJ’s] conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971).

DISABILITY STANDARD The Commissioner follows a five-step inquiry in evaluating claims for disability benefits under the Social Security Act: (1) Whether the claimant is currently employed; (2) whether the claimant has a severe impairment; (3) whether the claimant’s impairment is one that the Commissioner considers conclusively disabling; (4) if the claimant does not have a conclusively disabling impairment, whether she can perform her past relevant work; and (5) whether the claimant is capable of performing any work in the national economy.

Kastner v. Astrue, 697 F.3d 642, 646 (7th Cir. 2012). The claimant bears the burden of proof at every step except step five. Clifford v. Apfel, 227 F.3d 863, 868 (7th Cir. 2000). ANALYSIS Though an ALJ need not mention every piece of evidence in the record, “[a]n ALJ has the obligation to consider all relevant medical evidence and cannot simply cherry-pick facts that support a finding of non-disability while ignoring evidence that points to a disability finding.” Denton v. Astrue, 596 F.3d 419, 425 (7th Cir. 2010). Further, a social security claim is properly

remanded if the ALJ has mischaracterized the evidence such that the necessary logical bridge between evidence and conclusion does not exist. See Golembiewski v. Barnhart, 322 F.3d 912, 916-17 (7th Cir. 2003); Steele v. Barnhart, 290 F.3d 936, 941 (7th Cir. 2002). These errors infect the ALJ’s analysis of Plaintiff’s daily activities. Plaintiff, who lives with her parents, testified that household chores are shared. (AR 51). She cooks, but she does not clean the kitchen; her boyfriend does the laundry; her father does the yardwork; her mother takes care of the dog. (AR 51). On a given day, Plaintiff lies down to rest for an hour once daily and sits in a reclining chair twice daily for 30 minutes to an hour due to pain. (AR 52-53).

Plaintiff’s mother completed a Third Party Function Report. (AR 243-50). She described Plaintiff’s functioning as follows. Plaintiff spends twenty hours per day with her mother. (AR 243). Plaintiff cares for her children, prepares meals, does a little laundry, picks up after the children, watches television, and walks the children to the park or a store if it is nearby, but though Plaintiff bathes, feeds, reads to, plays with, and cleans up after her children, she receives help in all areas of childcare, as she can no longer run, jump, play, or lift. (AR 243-44). When Plaintiff plays with her children, it is about 45 minutes per day. (AR 247). Plaintiff cooks three meals per day five days per week, but it is all “easy stuff” like macaroni and cheese, hamburgers, frozen pizza, spaghetti, ramen noodles, cereal, toast, or pop-tarts, and it usually takes her an hour to make one of these simple meals. (AR 245). Though Plaintiff is able to pick up toys, sweep with a broom, wash dishes, do a little laundry and light cleaning, she has to take breaks in the middle of most housework, she has trouble bending and stooping, and she carries laundry in “half loads.” (AR 245). She cannot push a lawnmower, and she would have trouble with the accounting side of using a checkbook. (AR 246).

In the context of step 3, the ALJ noted that Plaintiff can prepare meals, care for her children, shop of groceries, and perform some housework. (AR 20). The ALJ referred to Plaintiff’s mother’s report that Plaintiff “bathes, feeds, cleans up after, reads to and plays with her children,” “prepares three meals a day on weekdays,” “picks up toys, sweeps with a broom, washes dishes, does a little laundry, and light cleaning.” (AR 20). The ALJ noted that Plaintiff testified that her boyfriend did the laundry. (AR 20). However, the ALJ’s summary was not a fair statement of the evidence, as she did not mention that Plaintiff receives help in all areas of childcare, takes breaks when performing household chores, and takes about an hour to prepare a simple meal. In the context of the RFC analysis, the ALJ reported that Plaintiff

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
Charles Kastner v. Michael Astrue
697 F.3d 642 (Seventh Circuit, 2012)
Denton v. Astrue
596 F.3d 419 (Seventh Circuit, 2010)
Mildred Thomas v. Carolyn Colvin
745 F.3d 802 (Seventh Circuit, 2014)
Nancy Thomas v. Carolyn Colvin
826 F.3d 953 (Seventh Circuit, 2016)

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Bluebook (online)
Davis v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/davis-v-commissioner-of-social-security-innd-2022.