Hultquist v. O'Malley

CourtDistrict Court, N.D. Illinois
DecidedFebruary 21, 2025
Docket1:22-cv-04588
StatusUnknown

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

Opinion

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

DAVID H., ) ) Plaintiff, ) Case No. 1:22-cv-4588 v. ) ) Magistrate Judge Jeannice W. Appenteng LELAND DUDEK, Acting ) Commissioner of Social Security,1 ) ) Defendant. )

MEMORANDUM OPINION AND ORDER

Plaintiff David H. seeks to overturn the final decision of the Commissioner of Social Security (“Commissioner”) denying his application for Disability Insurance Benefits (“DIB”) under Title II of the Social Security Act. The parties consented to the jurisdiction of the United States Magistrate Judge pursuant to 28 U.S.C. § 636(c), and plaintiff filed a brief explaining why the Commissioner’s decision should be reversed and the case remanded. The Commissioner responded with a competing motion for summary judgment in support of affirming the decision. After review of the record and the parties’ respective arguments, the Court grants the Commissioner’s motion. BACKGROUND Plaintiff protectively applied for DIB on December 19, 2019 alleging disability since December 1, 2018 due to motor vehicle accidents in 2011 and 2013,

1 Leland Dudek became the Acting Commissioner of Social Security on February 16, 2025. He is automatically substituted as the named defendant pursuant to FED. R. CIV. P. 25(d). lower back problems and chronic back pain, neuropathy and numbness in the left leg, numbness and tingling in the arms, a need to change positions frequently, and difficulty sleeping. Administrative Record (“R.”) 225, 258. Born in November 1967,

plaintiff was 51 years old as of the alleged onset date, making him a person closely approaching advanced age (age 50-54). 20 C.F.R. § 404.1563(d); R. 225. He was self- employed for many years performing landscaping, construction, and restoration work but he quit in December 2018 due to his impairments. R. 259-60. He has not engaged in substantial gainful activity since that date. R. 17. The Social Security Administration denied plaintiff’s application initially on

September 30, 2020, and upon reconsideration on March 3, 2021. R. 74-106. Plaintiff filed a timely request for a hearing and on August 9, 2021, he appeared before an administrative law judge (“ALJ”). R. 34. The ALJ heard testimony from plaintiff, who was represented by counsel, and from vocational expert Leida Woodham (the “VE”).2 R. 36-72. On August 25, 2021, the ALJ found that plaintiff’s degenerative disc disease of the lumbar and cervical spine and obesity are severe impairments, but that they do not alone or in combination with his non-severe

impairments meet or medically equal any of the listed impairments in 20 C.F.R. Part 404, Subpart P, Appendix 1. R. 17-20. After reviewing the evidence, the ALJ concluded that plaintiff has the residual functional capacity (“RFC”) to perform light work involving: occasional climbing of ramps and stairs; no climbing of ladders, ropes, or scaffolds; and

2 The hearing was held telephonically due to the COVID-19 pandemic. occasional stooping, kneeling, crouching, and crawling. R. 20-25. The ALJ accepted the VE’s testimony that a person with plaintiff’s background and this RFC could not perform plaintiff’s past landscape gardening work, but could perform a significant

number of other jobs available in the national economy. R. 25-27. As a result, the ALJ concluded that plaintiff was not disabled at any time from the alleged disability onset date through the date of the decision. R. 27. The Appeals Council denied plaintiff’s request for review on June 30, 2022. R. 1-5. That decision stands as the final decision of the Commissioner and is reviewable by this Court under 42 U.S.C. § 405(g). See Haynes v. Barnhart, 416 F.3d 621, 626 (7th Cir. 2005); Whitney

v. Astrue, 889 F. Supp. 2d 1086, 1088 (N.D. Ill. 2012). In support of his request for reversal or remand, plaintiff argues that the ALJ: (1) erred in rejecting the lifting restrictions set forth by consultative examiner William J. Lopez, M.D.; and (2) improperly discounted his subjective statements regarding his physical symptoms.3 For reasons discussed in this opinion, the Court finds that the ALJ’s decision is supported by substantial evidence. DISCUSSION

A. Standard of Review A claimant is disabled within the meaning of the Social Security Act if he is unable to perform “any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in

3 Arguments not specifically addressed in this opinion were not reasonably developed and have been waived. See, e.g., Crespo v. Colvin, 824 F.3d 667, 673 (7th Cir. 2016) (“perfunctory and undeveloped arguments, and arguments that are unsupported by pertinent authority, are waived”). death or which has lasted or can be expected to last for a continuous period of not less than 12 months.” 20 C.F.R. § 404.1505(a). In determining whether a claimant suffers from a disability, an ALJ must conduct a standard five-step inquiry, which

involves analyzing: “(1) whether the claimant is currently employed; (2) whether [the claimant] has a severe impairment or a combination of impairments that is severe; (3) whether [the claimant’s] impairments meet or equal any impairments listed as conclusively disabling; (4) whether [the claimant] can perform . . . past work; and (5) whether [the claimant] is capable of performing any work in the national economy.” Gedatus v. Saul, 994 F.3d 893, 898 (7th Cir. 2021) (citing 20

C.F.R. § 404.1520(a)-(g)). If the claimant meets his burden of proof at steps one through four, the burden shifts to the Commissioner at step five. Id. In reviewing an ALJ’s decision, the Court “will not reweigh the evidence, resolve debatable evidentiary conflicts, determine credibility, or substitute [its] judgment for the ALJ’s determination so long as substantial evidence supports it.” Warnell v. O’Malley, 97 F.4th 1050, 1052-53 (7th Cir. 2024) (quoting Gedatus, 994 F.3d at 900). Substantial evidence is “such relevant evidence as a reasonable mind

might accept as adequate to support a conclusion.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (citation omitted). “[S]ocial-security adjudicators are subject to only the most minimal of articulation requirements,” and ALJs need only 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.” Warnell, 97 F.4th at 1053-54 (internal quotations omitted) (in “shorthand terms,” an ALJ must build a “logical bridge from the evidence to his conclusion”); Morales v. O’Malley, 103 F.4th 469, 471 (7th Cir. 2024).

B. Analysis 1. Dr. Lopez’s Opinion Plaintiff argues that the case must be reversed or remanded because the ALJ erred in rejecting the lifting limitation set forth by Dr. William Lopez. Dkt. 11 at 7- 11; Dkt. 16 at 1-2. Since Plaintiff filed his claim in December 2019, the treating source rule used for claims filed before March 27, 2017 does not apply. This means

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