Harrison v. Social Security

CourtDistrict Court, N.D. Indiana
DecidedSeptember 29, 2025
Docket2:24-cv-00320
StatusUnknown

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

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA HAMMOND DIVISION

YVETTE N. HARRISON,

Plaintiff,

v. Case No. 2:24-CV-320 JD

COMMISSIONER OF SOCIAL SECURITY,

Defendant.

OPINION AND ORDER Plaintiff Yvette Harrison appeals the denial of her claims for disability insurance benefits under Title II and Title XVI of the Social Security Act. For the reasons below, the Court will remand this case to the Agency for additional consideration.

A. Procedural Background Ms. Harrison initially filed an application for disability insurance benefits in August 2021. The claim was denied about a year later, culminating in an appeal to the district court and a stipulated remand. On remand, Administrative Law Judge (“ALJ”) Dina LaMarche held a new hearing and subsequently issued another unfavorable decision. Ms. Harrison then filed the present appeal. She did not seek review of the ALJ’s decision by the Appeals Council, and the Appeals Council did not otherwise assume jurisdiction. Accordingly, the ALJ’s decision constitutes the final decision of the Commissioner, subject to judicial review under 42 U.S.C. § 405(g). See 20 C.F.R. § 404.984 (establishing procedures for federal court remand cases).

B. Standard of Review Because the Appeals Council denied review, the Court evaluates the ALJ’s decision as the final word of the Commissioner of Social Security. Schomas v. Colvin, 732 F.3d 702, 707 (7th Cir. 2013). This Court will affirm the Commissioner’s findings of fact and denial of benefits if they are supported by substantial evidence. Craft v. Astrue, 539 F.3d 668, 673 (7th Cir. 2008).

Substantial evidence consists of “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971). “The threshold for substantial evidence ‘is not high.’” Warnell v. O’Malley, 97 F.4th 1050, 1052 (7th Cir. 2024) (quoting Biestek v. Berryhill, 139 S.Ct. 1148, 1154 (2019)). This evidence must be “more than a scintilla but may be less than a preponderance.” Skinner v. Astrue, 478 F.3d 836, 841 (7th Cir. 2007). Even if “reasonable minds could differ” about the disability status of the claimant, the Court must affirm the Commissioner’s decision as long as it is adequately supported. Elder v. Astrue, 529 F.3d 408, 413 (7th Cir. 2008). The ALJ has the duty to weigh the evidence, resolve material conflicts, make independent findings of fact, and dispose of the case accordingly. Perales, 402 U.S. at 399–400.

In evaluating the ALJ’s decision, the Court considers the entire administrative record but does not reweigh evidence, resolve conflicts, decide questions of credibility, or substitute the Court’s own judgment for that of the Commissioner. Lopez ex rel. Lopez v. Barnhart, 336 F.3d 535, 539 (7th Cir. 2003). Still the Court conducts a “critical review of the evidence” before affirming the Commissioner’s decision. Id. An ALJ must evaluate both the evidence favoring the claimant and the evidence favoring the claim’s rejection and may not ignore an entire line of evidence that is contrary to his or her findings. Zurawski v. Halter, 245 F.3d 881, 887 (7th Cir. 2001). The ALJ must provide a “logical bridge” between the evidence and the conclusions. Terry v. Astrue, 580 F.3d 471, 475 (7th Cir. 2009). C. Standard for Disability Disability benefits are available only to those individuals who can establish disability under the Social Security Act. Estok v. Apfel, 152 F.3d 636, 638 (7th Cir. 1998). The claimant

must be unable “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). The Social Security regulations create a five-step process to determine whether the claimant qualifies as disabled. 20 C.F.R. §§ 404.1520(a)(4)(i)–(v); 416.920(a)(4)(i)– (v). The steps are to be used in the following order: 1. Whether the claimant is currently engaged in substantial gainful activity; 2. Whether the claimant has a medically severe impairment; 3. Whether the claimant’s impairment meets or equals one listed in the regulations; 4. Whether the claimant can still perform past relevant work; and

5. Whether the claimant can perform other work in the national economy. See Dixon v. Massanari, 270 F.3d 1171, 1176 (7th Cir. 2001). At step two, an impairment is severe if it significantly limits a claimant’s ability to do basic work activities. 20 C.F.R. §§ 404.1522(a), 416.922(a). At step three, a claimant is deemed disabled if the ALJ determines that the claimant’s impairment or combination of impairments meets or equals an impairment listed in the regulations. 20 C.F.R. §§ 404.1520(a)(4)(iii), 416.920(a)(4)(iii). If not, the ALJ must then assess the claimant’s residual functional capacity, which is defined as the most a person can do despite any physical and mental limitations that may affect what can be done in a work setting. 20 C.F.R. §§ 404.1545, 416.945. The ALJ uses the residual functional capacity to determine whether the claimant can perform his or her past work under step four and whether the claimant can perform other work in society at step five. 20 C.F.R. §§404.1520(e), 416.920(e). A claimant qualifies as disabled if he or she cannot perform such work. The claimant has the initial burden of proof at steps one through four, while the

burden shifts to the Commissioner at step five to show that there are a significant number of jobs in the national economy that the claimant can perform. Young v. Barnhart, 362 F.3d 995, 1000 (7th Cir. 2004).

D. The ALJ’s Decision Ms. Harrison filed a Title II and Title XVI application for disability benefits alleging disability beginning on February 9, 2020. In finding that Ms. Harrison wasn’t disabled, the ALJ employed the customary five-step analysis. At step two, she found that Ms.

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Related

Richardson v. Perales
402 U.S. 389 (Supreme Court, 1971)
James Young v. Jo Anne B. Barnhart
362 F.3d 995 (Seventh Circuit, 2004)
Roberta Skinner v. Michael J. Astrue, Commissioner
478 F.3d 836 (Seventh Circuit, 2007)
Terry v. Astrue
580 F.3d 471 (Seventh Circuit, 2009)
Craft v. Astrue
539 F.3d 668 (Seventh Circuit, 2008)
Elder v. Astrue
529 F.3d 408 (Seventh Circuit, 2008)
Jamie Adaire v. Carolyn Colvin
778 F.3d 685 (Seventh Circuit, 2015)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Schomas v. Colvin
732 F.3d 702 (Seventh Circuit, 2013)
McHenry v. Berryhill
911 F.3d 866 (Seventh Circuit, 2018)
Angela Crowell v. Kilolo Kijakazi
72 F.4th 810 (Seventh Circuit, 2023)
Brenda Warnell v. Martin J. O'Malley
97 F.4th 1050 (Seventh Circuit, 2024)

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