Franke v. Commissioner of Social Security

CourtDistrict Court, S.D. Illinois
DecidedAugust 22, 2022
Docket3:20-cv-00739
StatusUnknown

This text of Franke v. Commissioner of Social Security (Franke v. Commissioner of Social Security) is published on Counsel Stack Legal Research, covering District Court, S.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Franke v. Commissioner of Social Security, (S.D. Ill. 2022).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

TODD M. F.,1

Plaintiff, Case No. 20–CV–00739–JPG v.

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

MEMORANDUM & ORDER In accordance with 42 U.S.C. § 405(g), Plaintiff, represented by counsel, seeks judicial review of the final agency decision denying his applications for Disability Insurance Benefits (DIB) and a period of disability pursuant to 42 U.S.C. §§ 416(i) and 423 and Supplemental Security Income (SSI) pursuant to 42 U.S.C. §§ 1381a and 1382(a). Procedural History Plaintiff applied for DIB and SSI on May 6, 2014, alleging disability beginning March 24, 2011. The claim was denied on August 22, 2014. The Plaintiff filed a written request for a hearing and after holding an evidentiary hearing on April 4, 2017, Administrative Law Judge (ALJ) Kellie Wingate Campbell (“ALJ Campbell”) denied the application in a written decision dated May 3, 2017. (Tr. 16-24). The Appeals Council denied review on November 17, 2017. Plaintiff filed a complaint in this district asking the court to review the administrative decision and U.S. Magistrate Judge Clifford Proud issued remanded this case for a rehearing and reconsideration of the evidence.2 (Tr. 573-85). On remand, the ALJ held a second administration

1 The Court will not use plaintiff’s full name in this Memorandum and Order to protect the plaintiff’s privacy. See Fed. R. Civ. P. 5.2(c) and the Advisory Committee Notes thereto. 2 The magistrate judge remanded the decision denying plaintiff’s application for DIB because the vocational expert (“VE”) was not reliable and therefore the ALJ erred at step five on relying on the VE testimony because of an hearing in August 2019, during which Plaintiff and a vocational expert (“VE”) testified. (Tr. 512-538). ALJ Campbell issued a second decision dated September 18, 2019, denying the application for a second time. (Tr. 495-505). The ALJ found Plaintiff was not disabled, Plaintiff had performed substantial gainful activity (“SGA”) since his alleged onset date. (Tr. 497-98).

The ALJ found Plaintiff performed SGA from March 2011 to December 2011, noting Plaintiff admitted he worked full time on light duty and was let go after requesting two days of leave. (Tr. 497). ALJ found that Plaintiff’s left shoulder osteoarthritis and chondromalacia (status post arthroscopic surgeries), bilateral knee osteoarthritis, and obesity constituted severe impairments, but that none of Plaintiff’s impairments—singly or in combination—met or equaled the severity of any listed impairment. (Tr. 498-99). The ALJ found he had residual functional capacity (“RFC”) to perform light work subject to limitations such as: climbing ladders, ropes, scaffolds, no exposure to unprotected heights, climb ramps and stairs, stop and crouch, kneel or crawl, occasionally reach overheard with left arm. (Tr. 499, 503, 504). The Appeals Council denied review a second time on July 8, 2020, and the decision of

the ALJ became the final agency decision. (Tr. 1-6). Administrative remedies have been exhausted and a timely complaint was filed in this Court. Issues Raised by Plaintiff Plaintiff raises the following points: • Period of disability (POD) • The ALJ failed to properly evaluate residual functional capacity (RFC).

unresolved conflict between the VE testimony and the Dictionary of Occupational Titles (DOT). The magistrate judge expressly states that the court stresses its Order “should not be construed as an indication that the Court believes that plaintiff was disabled during the relevant time or that he should be awarded benefits. On the contrary, the Court has not formed any opinions in that regard and leaves those issues to be determined by the Commissioner after further proceedings.” See Memorandum and Order, Case No. 3:18-cv-00019-CJP (dated November 13, 2018). Applicable Legal Standards To qualify for benefits, a claimant must be “disabled” pursuant to the Social Security Act. The Act defines a “disability” as the “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 12 months.” 42 U.S.C. § 423(d)(1)(A).3 The physical or mental impairment must result from a medically demonstrable abnormality. 42 U.S.C. § 423(d)(3). Moreover, the impairment must prevent the plaintiff from engaging in significant physical or mental work activity done for pay or profit. 20 C.F.R. § 404.1572. Social Security regulations require an ALJ to ask five questions when determining whether a claimant is disabled. The first three questions are simple: (1) whether the claimant is presently unemployed; (2) whether the claimant has a severe physical or mental impairment; and (3) whether that impairment meets or is equivalent to one of the listed impairments that the regulations acknowledge to be conclusively disabling. 20 C.F.R. § 404.1520(a)(4); Weatherbee

v. Astrue, 649 F.3d 565, 569 (7th Cir. 2011). If the answers to these questions are “yes,” then the ALJ should find that the claimant is disabled. Id. At times, an ALJ may find that the claimant is unemployed and has a serious impairment, but that the impairment is neither listed in nor equivalent to the impairments in the regulations— failing at step three. If this happens, then the ALJ must ask a fourth question: (4) whether the claimant is able to perform his or her previous work. Id. If the claimant is not able to, then the

3 The statutes and regulations pertaining to DIB are found at 42 U.S.C. § 423 et seq. and 20 C.F.R. pt. 404. The statutes and regulations pertaining to SSI are found at 42 U.S.C. §§ 1382 and 1382c et seq. and 20 C.F.R. pt. 416. As is relevant to this case, the DIB and SSI statutes are materially the same. Jeske v. Saul, 955 F.3d 583, 587 (7th Cir. 2020). Furthermore, 20 C.F.R. § 416.925, which details medical considerations relevant to an SSI claim, relies on 20 C.F.R. Pt. 404, Subpt. P, the DIB regulations. Most citations herein are to the DIB regulations out of convenience.

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Franke v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/franke-v-commissioner-of-social-security-ilsd-2022.