Lola v. King

CourtDistrict Court, N.D. Illinois
DecidedJanuary 24, 2025
Docket1:22-cv-00120
StatusUnknown

This text of Lola v. King (Lola v. King) 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
Lola v. King, (N.D. Ill. 2025).

Opinion

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

BERNARD L.,

Plaintiff, No. 22 CV 00120 v. Magistrate Judge McShain MICHELLE KING, ACTING COMMISSIONER OF SOCIAL SECURITY,1

Defendant.

MEMORANDUM OPINION AND ORDER

Plaintiff Bernard L. brings this action for judicial review of the portion of the Social Security Administration’s (SSA) decision denying his application for benefits for the period from October 16, 2012 to April 3, 2013. For the following reasons, plaintiff’s request to reverse the SSA’s decision [15]2 is denied, defendant’s motion for summary judgment [16] is granted, and the decision denying the application for benefits for the period of October 16, 2012, to April 3, 2013, is affirmed.

Background

On May 10, 2013, plaintiff filed a Title II application for a period of disability and disability insurance benefits, alleging a disability onset date of October 16, 2012. [10-1] 15; [10-2] 1340. Plaintiff’s claims were denied initially on July 16, 2013, and upon reconsideration on March 28, 2014. [10-1] 15. Plaintiff requested a hearing, which was held on December 9, 2015 before administrative law judge (ALJ) Kadlec. [Id.] 15, 39–90. On February 17, 2016, ALJ Kadlec issued an unfavorable decision finding plaintiff not disabled. [Id.] 15–33. The Appeals Council denied review on March 2, 2017, and plaintiff appealed to the Northern District of Illinois. [Id.] 1; [10- 2] 1056–57. On November 17, 2017, on the Commissioner’s agreed motion, the District Court remanded for further administrative proceedings. [10-2] 1052–55.

1 In accordance with Fed. R. Civ. P. 25(d), Michelle King, the Acting Commissioner of Social Security, is substituted as the defendant in this case in place of the former Commissioner of Social Security, Martin O’Malley. 2 Bracketed numbers refer to entries on the district court docket. Referenced page numbers are taken from the CM/ECF header placed at the top of filings, except for citations to the administrative record [10], which refer to the page numbers in the bottom right corner of each page. On April 11, 2018, the Appeals Council vacated the final decision and remanded to an ALJ. [10-2] 1075–77. The Appeals Council also noted that plaintiff had filed a subsequent claim for Title II disability benefits on May 22, 2017 and the state agency had determined that plaintiff was disabled as of February 18, 2016. [Id.] 1076. The Appeals Council affirmed this determination but found that the period prior to February 18, 2016 required further adjudication. [Id.] 1076–77. A second, supplemental hearing was held before ALJ Kadlec on September 25, 2018. [Id.] 943, 969–1022. On December 3, 2018, ALJ Kadlec issued a decision finding plaintiff disabled as of June 26, 2015 but not disabled prior to that date. [Id.] 942–61. The Appeals Council denied further review and plaintiff appealed again to the District Court. [Id.] 1427. On November 30, 2020, this Court reversed the agency’s decision and remanded for further administrative proceedings. [Id.] 1427–41. On March 11, 2021, the Appeals Council affirmed the prior finding that plaintiff was disabled as of June 26, 2015 and remanded to an ALJ for review of the period prior to June 26, 2015, i.e., October 16, 2012 through June 25, 2015. [Id.] 1442–44.

A hearing was held before ALJ Ellis on June 16, 2021. [10-2] 1340, 1363–83. In a decision dated June 30, 2021, the ALJ found that plaintiff was not disabled prior to April 4, 2013, but became disabled on that date and continued to be disabled through the date of the decision. [Id.] 1340–53. The Appeals Council denied review on November 3, 2021, [id.] 1328–29, rendering the ALJ’s decision the final decision of the Commissioner. [Id.] 1–4. See 20 C.F.R. §§ 404.955 & 404.981; Gedatus v. Saul, 994 F.3d 893, 898 (7th Cir. 2021). Plaintiff timely appealed to this Court [1], and the Court has subject-matter jurisdiction to review the Commissioner’s decision under 42 U.S.C. § 405(g).3

Legal Standard

In evaluating a claim for disability benefits, ALJs follow a five-step, sequential process. Apke v. Saul, 817 F. App’x 252, 255 (7th Cir. 2020). The ALJ must evaluate the following:

(1) whether the claimant is currently [un]employed; (2) whether the claimant has a severe impairment; (3) whether the claimant’s impairment meets or equals one of the impairments listed by the [Commissioner] ...; (4) whether the claimant can perform her past work; and (5) whether the claimant is capable of performing work in the national economy.

Fetting v. Kijakazi, 62 F.4th 332, 336 (7th Cir. 2023) (alterations in original) (quoting Clifford v. Apfel, 227 F.3d 863, 868 (7th Cir. 2000)). See also 20 C.F.R. § 404.1520. The claimant bears the burden of proof at steps one through four. Fetting, 62 F.4th

3 The parties have consented to the exercise of jurisdiction in this case by a United States Magistrate Judge [6]. at 336 (citing Clifford, 227 F.3d at 868). “At step five, the burden shifts to the agency to show that ‘there are significant numbers of jobs in the national economy for someone with the claimant’s abilities and limitations.’” Id. at 336–37 (quoting Ruenger v. Kijakazi, 23 F.4th 760, 761 (7th Cir. 2022) (citing 20 C.F.R. § 416.960(c)(2)).

When the Appeals Council denies a plaintiff’s request for review, the ALJ’s decision constitutes the final decision of the Commissioner. Gedatus, 994 F.3d at 898. Courts “apply a very deferential standard of review to the ALJ’s decision.” Jarnutowski v. Kijakazi, 48 F.4th 769, 773 (7th Cir. 2022) (citation and internal quotations omitted). In its “extremely limited” role, id., the Court must “ensur[e] that substantial evidence supported the ALJ’s decision and that the ALJ applied the correct legal standards.” Morales v. O’Malley, 103 F.4th 469, 472 (7th Cir. 2024) (citing Stephens v. Berryhill, 888 F.3d 323, 327 (7th Cir. 2018)). “A reviewing 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.’” Chavez v. O’Malley, 96 F.4th 1016, 1021 (7th Cir. 2024) (alteration in original) (quoting Gedatus, 994 F.3d at 900). See also Stephens, 888 F.3d at 327 (“Although this Court reviews the record as a whole, it cannot substitute its own judgment for that of the SSA by reevaluating the facts, or reweighing the evidence to decide whether a claimant is in fact disabled.”).

Substantial evidence is “not a high threshold: it means only ‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Karr v. Saul, 989 F.3d 508, 511 (7th Cir. 2021). “An ALJ need not specifically address every piece of evidence, but must provide a ‘logical bridge’ between the evidence and [her] conclusions.” Bakke v. Kijakazi, 62 F.4th 1061, 1066 (7th Cir. 2023).

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Lola v. King, Counsel Stack Legal Research, https://law.counselstack.com/opinion/lola-v-king-ilnd-2025.