Johnson v. Commissioner of Social Security

CourtDistrict Court, S.D. Illinois
DecidedApril 6, 2022
Docket3:20-cv-00722
StatusUnknown

This text of Johnson v. Commissioner of Social Security (Johnson 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
Johnson v. Commissioner of Social Security, (S.D. Ill. 2022).

Opinion

UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF ILLINOIS

MICHAEL J. J.,1

Plaintiff,

v. Case No. 20-cv-722-JPG

KILOLO KIJAKAZI, Acting Commissioner of Social Security,

Defendant.

MEMORANDUM AND 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 in August 2017 alleging disability beginning November 14, 2015. After holding an evidentiary hearing in April 2019, ALJ Michael D. Shilling denied the application in a written decision dated June 19, 2019. (Tr. 12-40.) The Appeals Council denied review, 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: • the ALJ erred in evaluating Plaintiff’s subjective symptoms;

• the ALJ failed to include all of Plaintiff’s mental limitations in the Residual Functional Capacity (RFC) assessment and in the hypotheticals to the Vocational Expert (VE); and

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. • the ALJ erred in not inquiring further into an alleged conflict between the VE’s testimony and the conditions of the jobs identified.

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).2 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—

2 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. 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 burden shifts to the Commissioner to answer a fifth and final question: (5) whether the claimant is capable of performing any work within the economy, in light of the claimant’s age, education, and work experience. If the claimant cannot, then the ALJ should find the claimant to be disabled.

Id.; see also Simila v. Astrue, 573 F.3d 503, 512-13 (7th Cir. 2009); Zurawski v. Halter, 245 F.3d 881, 886 (7th Cir. 2001). A claimant may appeal the final decision of the Social Security Administration to this Court, but the scope of review here is limited: while the Court must ensure that the ALJ did not make any errors of law, the ALJ’s findings of fact are conclusive as long as they are supported by “substantial evidence.” 42 U.S.C. § 405(g). Substantial evidence is evidence that a reasonable person would find sufficient to support a decision. Weatherbee, 649 F.3d at 568 (citing Jens v. Barnhart, 347 F.3d 209, 212 (7th Cir. 2003)). The Court takes into account the entire administrative record when reviewing for substantial evidence, but it does not reweigh evidence,

resolve conflicts, decide questions of credibility, or substitute its own judgment for that of the ALJ. Brewer v. Chater, 103 F.3d 1384, 1390 (7th Cir. 1997); Moore v. Colvin, 743 F.3d 1118, 1121 (7th Cir. 2014). But even though this judicial review is limited, the Court should not and does not act as a rubber stamp for the Commissioner. Parker v. Astrue, 597 F.3d 920, 921 (7th Cir. 2010). The Decision of the ALJ ALJ Shilling followed the five-step analytical framework described above.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Weatherbee v. Astrue
649 F.3d 565 (Seventh Circuit, 2011)
Parker v. Astrue
597 F.3d 920 (Seventh Circuit, 2010)
Simila v. Astrue
573 F.3d 503 (Seventh Circuit, 2009)
Villano v. Astrue
556 F.3d 558 (Seventh Circuit, 2009)
Kip Yurt v. Carolyn Colvin
758 F.3d 850 (Seventh Circuit, 2014)
Jennifer Moore v. Carolyn Colvin
743 F.3d 1118 (Seventh Circuit, 2014)
Alejandro Moreno v. Nancy Berryhill
882 F.3d 722 (Seventh Circuit, 2018)
Biestek v. Berryhill
587 U.S. 97 (Supreme Court, 2019)
Michelle Jeske v. Andrew M. Saul
955 F.3d 583 (Seventh Circuit, 2020)
Chic Zoch v. Andrew Saul
981 F.3d 597 (Seventh Circuit, 2020)
Andrew Pavlicek v. Andrew Saul
994 F.3d 777 (Seventh Circuit, 2021)
Brenda Wilder v. Kilolo Kijakazi
22 F.4th 644 (Seventh Circuit, 2022)
Schomas v. Colvin
732 F.3d 702 (Seventh Circuit, 2013)

Cite This Page — Counsel Stack

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