Locke v. O'Malley

CourtDistrict Court, N.D. Illinois
DecidedFebruary 10, 2025
Docket1:23-cv-11667
StatusUnknown

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

Opinion

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

LIONEL L.,1 ) ) Plaintiff, ) ) No. 23 C 11667 v. ) ) Magistrate Judge Gabriel A. Fuentes MICHELLE A. KING, ) Acting Commissioner of Social Security,2 ) ) Defendant. )

MEMORANDUM OPINION AND ORDER3

Before the Court is Lionel L.’s memorandum in support of reversing or remanding the Commissioner’s decision denying his application for Social Security disability benefits (D.E. 13) and Defendant’s motion to affirm the Commissioner’s decision (D.E. 18). I. Procedural History Plaintiff applied for disability insurance benefits (“DIB”) on April 8, 2019.4 (R. 15, 2549.) In January 2021, after a hearing, a (different) ALJ denied Plaintiff’s application, finding Plaintiff was not disabled between his alleged onset date (“AOD”) of October 27, 2012, and the date last

1 The Court in this order is referring to Plaintiff by his first name and first initial of his last name in compliance with Internal Operating Procedure No. 22 of this Court. To the extent the Court uses pronouns in this order, the Court uses those pronouns used by the parties in their memoranda.

2 The Court substitutes Michelle A. King for her immediate predecessor, Carolyn W. Colvin, as the proper defendant in this action pursuant to Federal Rule of Civil Procedure 25(d) (a public officer’s successor is automatically substituted as a party).

3 On January 3, 2024, by consent of the parties and pursuant to 28 U.S.C. § 636(c) and Local Rule 73.1, this case was reassigned to this Court for all proceedings, including entry of final judgment. (D.E. 11.)

4 Plaintiff’s initial alleged onset of disability date was August 26, 2008, which he first amended to October 27, 2012 (R. 15) and subsequently amended to June 12, 2013. (R. 2535-36.) insured (“DLI”) of December 31, 2012. 5 Plaintiff appealed, which ultimately led to an agreed remand by the district court in April 2022. (R. 12-33; 2626-28.) In its remand order, the Appeals Council (“AC”) vacated the final decision, determining that the prior ALJ did not adequately consider the issue of borderline age,6 and improperly established the DLI without reviewing a

complete record of Plaintiff’s earnings. (R. 2631-32.) The AC directed the ALJ to (1) give further consideration to Plaintiff’s earning records and DLI; (2) give further consideration to the issue of borderline age, if necessary; and (3) if warranted, obtain supplemental vocational testimony to determine Plaintiff’s occupational base. Id. Subsequent to the AC’s remand order, Plaintiff amended the AOD to June 12, 2013, his 55th birthday, thus removing the borderline age issue. (R. 2535, 2562.) Updated earnings records were provided to the ALJ, updating the DLI from December 31, 2012, to December 31, 2013. (R. 2535-36, citing R. 2759-62.) Therefore, the amended application presented a very narrow question of whether Plaintiff was disabled during the roughly six-month period from June 12, 2013, to December 31, 2013.

After remand, on February 7, 2023, Plaintiff and a vocational expert (“VE”) testified at a hearing before the current ALJ. (R. 2556-90.) On May 18, 2023, the ALJ issued a written decision denying Plaintiff’s application, finding him not disabled under the Social Security Act (the “Act”).7 (R. 2532-2555.) This appeal followed.

5 To be entitled to DIB, a claimant must prove that their disability onset date preceded the DLI. See Martin v. Kijakazi, 88 F.4th 726, 728 (7th Cir. 2023), citing 42 U.S.C. § 423(c).

6 Plaintiff was less than six months away from turning 55 years old as of the prior December 31, 2012, DLI. (R. 2535.) After Plaintiff amended the AOD to June 12, 2013, his 55th birthday, the consideration of borderline age issue was no longer necessary as Plaintiff was in the advanced age category from the AOD of June 12, 2013, to the DLI of December 31, 2013. (Id.)

7 On September 13, 2023, after the ALJ’s decision became final, Plaintiff filed this civil action in federal district court. See R. 2533: “If you do not file written exceptions and the Appeals Council does not review II. The ALJ Decision The Administrative Law Judge (“ALJ”) applied the Social Security Administration’s (“SSA”) five-step sequential evaluation process to Plaintiff’s claims. At Step One, the ALJ found Plaintiff had not engaged in substantial gainful activity from his AOD of June 12, 2013, through

his DLI of December 31, 2013. (R. 2538.) At Step Two, the ALJ determined that Plaintiff had the severe impairments of arthritis and degenerative joint disease.8 Id. As to Plaintiff’s mental impairments of depression, anxiety, and post-traumatic stress disorder, the ALJ determined they were non-severe. (R. 2538.) The ALJ found Plaintiff had only mild limitations in all four of the “Paragraph B” functional areas: understanding, remembering, or applying information; interacting with others; concentrating, persisting or maintaining pace; and adapting or managing oneself. (R. 2539.) At Step Three, the ALJ found that Plaintiff’s impairments alone or in combination did not meet or medically equal any Listing. (R. 2540.) The ALJ assessed Plaintiff as having the ability to perform light work “with exceptions” and assigned Plaintiff a residual functional capacity (“RFC”) as follows:

occasionally balance, kneel, crouch, crawl, climb ramps and stairs, and climb ladders, ropes, or scaffolds; no excessive noise; no prolonged exposure to high concentration of odors, fumes, and gases; no unprotected heights.

(R. 2541.)

my decision on its own, my decision will become final on the 61st day following the date of this notice. After my decision becomes final, you will have 60 days to file a new civil action in Federal district court.”

8 The previous ALJ determined in her January 29, 2021, decision at Step Two that Plaintiff had the severe impairments of migraines, arthritis of the hands, degenerative joint disease of the knees bilaterally, obesity, depression, anxiety, and post-traumatic stress disorder. (R. 17, 29.) At Step Four, the ALJ found that Plaintiff was capable of performing his past relevant work as a telephone solicitor, order clerk, and deputy coroner (R. 2548.) Thus, the ALJ determined that Plaintiff was not disabled under the Act. (R. 2548.) III. Legal Standard

An ALJ’s decision will be affirmed if it is supported by “substantial evidence,” which means “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019). “[T]he threshold for such evidentiary sufficiency is not high.” Id. As the Seventh Circuit has made clear, ALJs are “subject to only the most minimal of articulation requirements” and “need not address every piece or category of evidence identified by a claimant, fully summarize the record, or cite support for every proposition or chain of reasoning.” Warnell v. O’Malley, 97 F.4th 1050, 1053 (7th Cir. 2024). “All we require is that ALJs 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.” Id. at 1054. The Seventh Circuit added that “[a]t times,

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Bluebook (online)
Locke v. O'Malley, Counsel Stack Legal Research, https://law.counselstack.com/opinion/locke-v-omalley-ilnd-2025.