Jenkins-Cotton v. Commissioner of Social Security

CourtDistrict Court, S.D. Illinois
DecidedMarch 27, 2025
Docket3:23-cv-03817
StatusUnknown

This text of Jenkins-Cotton v. Commissioner of Social Security (Jenkins-Cotton 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
Jenkins-Cotton v. Commissioner of Social Security, (S.D. Ill. 2025).

Opinion

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

LETITIA J.,1 ) ) Plaintiff, ) ) v. ) Case No. 23-cv-3817-RJD2 ) COMMISSIONER of SOCIAL SECURITY, ) ) Defendant. ) )

ORDER

DALY, Magistrate Judge:

In accordance with 42 U.S.C. § 405(g), Plaintiff seeks judicial review of the final agency decision denying her application for Disability Insurance Benefits (DIB) pursuant to 42 U.S.C. § 423. Procedural History Plaintiff applied for DIB in May 2021, alleging an onset date of March 25, 2021. Tr. 17. After holding an evidentiary hearing on April 18, 2023, ALJ Scot Gulick denied the application. Tr. 26. The Appeals Council denied Plaintiff’s request for review, making the ALJ’s decision final and subject to judicial review. Tr. 1. Plaintiff filed a timely Complaint with this Court. Issues Raised by Plaintiff Plaintiff makes the following arguments: 1. The residual functional capacity (“RFC”) is not supported by substantial evidence.

1 In keeping with the court’s practice, Plaintiff’s full name will not be used in this Order due to privacy concerns. See Advisory Committee Notes to Fed. R. Civ. P. 5.2(c).

2 Pursuant to 28 U.S.C. §636(c), this case was assigned to the undersigned for final disposition upon consent of the parties. Doc. 10. Page 1 of 12 2. The ALJ failed to properly consider the medical opinions.

3. The ALJ failed to properly consider Plaintiff’s subjective complaints of pain.

Applicable Legal Standards To qualify for DIB, a claimant must be disabled within the meaning of the applicable statutes and regulations. The statutes and regulations pertaining to DIB are found at 42 U.S.C. § 423, et seq., and 20 C.F.R. pt. 404. 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). To determine whether a claimant is disabled, the ALJ considers the following five questions in order: (1) is the claimant doing substantial gainful activity?; (2) does the claimant have a severe medically determinable physical or mental impairment?; (3) does the impairment meet or medically equal one of a list of specific impairments enumerated in the regulations?; (4) is the claimant able to perform his former occupation?; and (5) is the claimant able to perform any other work? 20 C.F.R. § 404.1520(a)(4). An affirmative answer at step 1 or step 4 or step 5 precludes a finding of disability. Id. This Court determines whether the ALJ’s findings were supported by substantial evidence and whether any errors of law were made. Tutweiler v. Kijakazi, 87 F. 4th 853, 857 (7th Cir. 2023) (internal citations and quotations omitted). Substantial evidence is defined as “relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Id. In reviewing for “substantial evidence,” the entire administrative record is taken into consideration, Page 2 of 12 but this Court does not reweigh evidence, resolve conflicts, decide questions of credibility, or substitute its own judgment for that of the ALJ. Warnell v. O’Malley, 97 F.4th 1050, 1052 (7th Cir. 2023) (internal citations and quotations omitted). However, the undersigned does not act as a rubber stamp for the Commissioner. See Minnick v. Colvin, 775 F.3d 929, 935 (7th Cir. 2015). There must be a “logical bridge” between the ALJ’s conclusion and the evidence. Hess v.

O’Malley, 92 F. 4th 671, 676-77 (7th Cir. 2024) (citing Jeske v. Saul, 955 F.3d 583, 587 (7th Cir. 2020)). The Decision of the ALJ The ALJ followed the required five-step analytical framework. He determined that Plaintiff had not engaged in substantial gainful activity since March 25, 2021. Tr. 19. The ALJ found that Plaintiff has severe impairments of obesity, degenerative disc disease of the lumbar spine, and hypertension. Tr. 19. However, he found that Plaintiff does “not have an impairment or combination of impairments that meets or medically equals one of the listed impairments.” Tr. 20.

The ALJ found that Plaintiff has the residual functional capacity to: Perform light work…in that she can lift and/or carry up to 20 pounds occasionally and 10 pounds frequently; she can stand and/or walk for 6 hours in an 8-hour workday; and she can sit for 6 hours in an 8-hour workday. She can occasionally stoop, crawl, and/or climb ladders, ropes, or scaffolds; and she can frequently kneel, crouch and/or climb ramps and stairs. She must avoid concentrated exposure to unprotected heights, moving mechanical parts, extreme cold and vibration.

Tr. 20. Based on the testimony of a vocational expert, the ALJ concluded that Plaintiff is unable to perform past relevant work yet concluded there are jobs that exist in significant numbers in the national economy that Plaintiff can perform. Tr. 23-24.

Page 3 of 12 The Evidentiary Record The Court reviewed and considered the entire evidentiary record in formulating this Order. The following summary of the record is tailored to Plaintiff’s arguments. 1. Evidentiary Hearing Plaintiff testified that she worked for the United States Postal Service from 2015-2021.

Tr. 40. She delivered mail and packages to customers in rural areas. Tr. 40. She explained that she cannot currently work a full-time job because of back pain and her legs (particularly her left) give out. Tr. 44, 45. She underwent physical therapy and “it helped to relax some of the pain… but it came back not long after.” Tr. 48. She takes pain medication three times a day that makes her tired. Tr. 48. She has high blood pressure because of her back pain. Tr. 45. High blood pressure is problematic because she has also been diagnosed with chronic kidney disease, and her doctor told her that high blood pressure would negatively impact her kidneys. Tr. 48. Plaintiff rarely drives because she is afraid of her leg “going out.” Tr. 51. She can drive to church, but it is only four blocks from her house. Tr. 51. When she is doing housework, she

can stand for approximately 15 minutes before she needs to sit down. Tr. 49, 50. Tr. 50. She can sit in a “typical office chair” for approximately 20 minutes. Tr. 50. She can only prepare simple food, like boiling an egg. Tr. 50. Housecleaning is a lengthy process because she must sit and rest. Tr. 51. She cannot change the sheets on her bed or transfer wet/heavy clothing from the washer to the dryer. Tr. 51. A friend lives with her and helps around the house. Tr. 50. She rarely goes into the grocery store; “most of the time someone else goes in and get[s]” the groceries. Tr. 52. The ALJ elicited the following testimony from Plaintiff regarding outside activities:

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Related

Daniel Minnick v. Carolyn Colvin
775 F.3d 929 (Seventh Circuit, 2015)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Michelle Jeske v. Andrew M. Saul
955 F.3d 583 (Seventh Circuit, 2020)
Heather Tutwiler v. Kilolo Kijakazi
87 F.4th 853 (Seventh Circuit, 2023)
Todd Hess v. Martin J. O'Malley
92 F.4th 671 (Seventh Circuit, 2024)
Brenda Warnell v. Martin J. O'Malley
97 F.4th 1050 (Seventh Circuit, 2024)

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Jenkins-Cotton v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/jenkins-cotton-v-commissioner-of-social-security-ilsd-2025.