Mann v. Commissioner of Social Security

CourtDistrict Court, S.D. Illinois
DecidedSeptember 25, 2023
Docket3:22-cv-01799
StatusUnknown

This text of Mann v. Commissioner of Social Security (Mann 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
Mann v. Commissioner of Social Security, (S.D. Ill. 2023).

Opinion

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

TAMMY S. M.1, Plaintiff, v. Case No. 22-cv-01799-SPM KILOLO KIJAKAZI, Acting Commissioner of Social Security,

Defendant. MEMORANDUM AND ORDER

McGLYNN, District 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) benefits pursuant to 42 U.S.C. § 423 and 42 U.S.C. §§ 1382 and 1382c, respectively2 (Doc. 1). PROCEDURAL HISTORY In December 20193, plaintiff applied for DIB, alleging a disability onset date of

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

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 and regulations are identical. Furthermore, 20 C.F.R. § 416.925 detailing 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.

3 Administrative Law Judge Jason Yoder indicated that “On December 17, 2019, the claimant protectively filed a Title II application for a period of disability and disability insurance benefits, Page 1 of 15 December 26, 2019. (Tr. 18). On August 18, 2020, plaintiff was advised that she did not qualify for benefits and her claim was disapproved. (Tr. 107-110). On November 13, 2020, plaintiff requested reconsideration. (Tr. 112-113). On April 24, 2021,

plaintiff was advised that her claim had been independently reviewed; however, the previous denial was found to be correct. (Tr. 114-118). On June 17, 2021, plaintiff requested a hearing before an Administrative Law Judge (“ALJ”) because she disagreed with the determination and claimed to be disabled. (Tr. 121-122). After holding an evidentiary hearing on September 23, 2021, the ALJ denied the application on October 20, 2021. (Tr. 15-33). Plaintiff requested review of the ALJ’s

decision, but the Appeals Council denied plaintiff’s request for review on June 22, 2022. (Tr. 1-6). In accordance with the foregoing, the ALJ’s decision is the final agency decision subject to judicial review. Plaintiff has exhausted administrative remedies and filed a timely complaint with this Court (Doc. 1). ISSUES RAISED BY PLAINTIFF In her brief, plaintiff indicates that there are two primary issues to be decided: 1. Whether the ALJ violated Social Security Ruling (SSR) 96-8p by not providing a narrative discussion describing how the evidence supported the particularized manipulative findings; and,

2. Whether the ALJ violation SSR 16-3p by improperly relying on a purported lack of treatment and the receipt of unemployment benefits, while failing to assess plaintiff’s daily activities and work history.

alleging disability beginning December 26, 2019 however, the Application for Disability Insurance Benefits was completed on January 13, 2020. (Tr. 181-187). Page 2 of 15 APPLICABLE LEGAL STANDARDS

To qualify for DIB or SSI, a claimant must be disabled within the meaning of the applicable statutes. Under the Social Security Act, a person is disabled if he/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 employs a “five-step sequential evaluation process.” See 20 C.F.R. §§ 404.1520 (a)(1), (2), (4); 416.920(a)(1),

(4). Accordingly, the ALJ considers the following five questions in order: (1) whether the claimant is doing substantial gainful activity; (2) whether the claimant has a severe medically determinable physical or mental impairment that meets certain duration requirements or a combination of impairments that is severe and meets the duration requirements; (3) whether the claimant has an impairment that meets or equals one of the impairments listed in the regulations and satisfies the duration requirements; (4) whether, in view of the claimant’s residual functional capacity

(“RFC”) and past relevant work, he or she can perform past relevant work; and (5) whether, in view of the claimant’s RFC, age, education, and work experience, he or she can adjust to other work. See 20 C.F.R. §§ 404.1520(a)(4); 416.920(a)(4); see also Young v. Barnhart, 362 F.3d 995, 1000 (7th Cir. 2004). If the claimant is doing substantial gainful activity under step 1, does not have an impairment or combination of impairments as described at step 2, can perform Page 3 of 15 past relevant work under step 4, or can adjust to other work under step 5, then the claimant is not disabled. See 20 C.F.R. §§ 404.1520(a)(4)(i),(ii), (iv), (v); 416.920(a)(4)(i), (ii), (iv), (v). In other words, an affirmative answer at either step 3 or

step 5 leads to a finding that the claimant is disabled and/or a negative answer at any step, other than at step 3, precludes a finding of disability. The claimant bears the burden of proof at steps 1–4. Mandrell v. Kijakazi, 25 F.4th 514, 516 (7th Cir. 2022). Once the claimant shows an inability to perform past work, the burden then shifts to the Commissioner to show the claimant’s ability to engage in other work existing in significant numbers in the national economy. Zurawski v. Halter, 245 F.3d

881, 886 (7th Cir. 2001). A claimant’s impairments and related symptoms may cause physical and mental limitations that affect what may be done in a work setting. See 20 C.F.R. §§ 404.1545(a)(1); 416.945(a)(1). The RFC at issue in steps 4 and 5 assesses the most that a claimant can do in a work setting, notwithstanding those limitations. See 20 C.F.R.

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Mann v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/mann-v-commissioner-of-social-security-ilsd-2023.