MAXEY v. KIJAKAZI

CourtDistrict Court, S.D. Indiana
DecidedSeptember 16, 2022
Docket1:21-cv-00686
StatusUnknown

This text of MAXEY v. KIJAKAZI (MAXEY v. KIJAKAZI) is published on Counsel Stack Legal Research, covering District Court, S.D. Indiana primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
MAXEY v. KIJAKAZI, (S.D. Ind. 2022).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

VIVIAN M.,1 ) ) Plaintiff, ) ) v. ) No. 1:21-cv-00686-DML-JRS ) KILOLO KIJAKAZI, Acting Commissioner ) of Social Security,2 ) ) Defendant. )

Order on Complaint for Judicial Review

Vivian M. filed for supplemental security income ("SSI") from the Social Security Administration ("SSA") on September 21, 2018, alleging an onset date of September 21, 2018. [Tr. 15.] Her application was initially denied on January 17, 2019 [Tr. 105], and upon reconsideration on April 30, 2019 [Tr. 117]. Administrative Law Judge Livia Morales (the "ALJ") conducted a hearing on July 21, 2020. [Tr. 34–75.] On August 24, 2020, the ALJ issued a decision that concluded that Vivian was not disabled. [Tr. 12–27.] The Appeals Council denied review on January 22, 2021. [Tr. 1.] On March 22, 2020, Vivian timely filed this

1 To protect the privacy interests of claimants for Social Security benefits, and consistent with the recommendation of the Court Administration and Case Management Committee of the Administrative Office of the United States Courts, the Southern District of Indiana uses only first names and last initials of non- governmental parties in Social Security judicial review opinions.

2 According to Federal Rule of Civil Procedure 25(d), Kilolo Kijakazi automatically became the Defendant in this case when she was named as the Acting Commissioner of the SSA. civil action asking the court to review the denial of benefits according to 42 U.S.C. §§ 405(g) and 1383(c). [Filing No. 1.] Standard for Proving Disability

To prove disability, a claimant must show she is unable 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. § 1382c(a)(3)(A). Vivian is disabled if her impairments are of such severity that she is not able to perform the work she previously engaged in and, if based on

her age, education, and work experience, she cannot engage in any other kind of substantial gainful work that exists in significant numbers in the national economy. Id. at 1382c(a)(3)(B). The SSA has implemented these statutory standards by, in part, prescribing a five-step sequential evaluation process for determining disability. 20 C.F.R. § 416.920. Step one asks if the claimant is currently engaged in substantial gainful activity; if she is, then she is not disabled. Step two asks whether the claimant's

impairments, singly or in combination, are severe; if they are not, then she is not disabled. A severe impairment is one that "significantly limits [a claimant's] physical or mental ability to do basic work activities." Id. at 416.920(c). The third step is an analysis of whether the claimant's impairments, either singly or in combination, meet or medically equal the criteria of any of the conditions in the Listing of Impairments, 20 C.F.R. Part 404, Subpart P, Appendix 1. The Listing of Impairments includes medical conditions defined by criteria that the SSA has pre- determined are disabling, so that if a claimant meets all the criteria for a listed impairment or presents medical findings equal in severity to the criteria for the

most similar listed impairment, then the claimant is presumptively disabled and qualifies for benefits. Sims v. Barnhart, 309 F.3d 424, 428 (7th Cir. 2002). If the claimant's impairments do not satisfy a listing, then her residual functional capacity ("RFC") is determined for purposes of steps four and five. RFC is a claimant's ability to do work on a regular and continuing basis despite her impairment-related physical and mental limitations. 20 C.F.R. § 416.945. At the

fourth step, if the claimant has the RFC to perform her past relevant work, then she is not disabled. The fifth step asks whether there is work in the relevant economy that the claimant can perform, based on her age, work experience, and education (which are not considered at step four), and her RFC; if so, then she is not disabled. The individual claiming disability bears the burden of proof at steps one through four. Bowen v. Yuckert, 482 U.S. 137, 146 n.5 (1987). If the claimant meets that burden, then the Commissioner has the burden at step five to show that work exists

in significant numbers in the national economy that the claimant can perform, given her age, education, work experience, and functional capacity. 20 C.F.R. § 416.960(c)(2); Young v. Barnhart, 362 F.3d 995, 1000 (7th Cir. 2004).3

3 The Code of Federal Regulations contains separate, parallel sections concerning disability insurance benefits and SSI, which are identical in most respects. Cases like Young may reference the section pertaining to only one type of benefits. 362 F.3d at 1000 (citing 20 C.F.R. § 404.1520 (for disability insurance benefits)). Generally, a verbatim section exists establishing the same legal point with both Standard for Review of the ALJ's Decision

Judicial review of the Commissioner's (or ALJ's) factual findings is deferential. A court must affirm if no error of law occurred and if the findings are supported by substantial evidence. Dixon v. Massanari, 270 F.3d 1171, 1176 (7th Cir. 2001). Substantial evidence means evidence that a reasonable person might accept as adequate to support a conclusion. Biestek v. Berryhill, 139 S. Ct. 1148, 1154 (2019) (internal quotation and citation omitted). The standard demands more than a scintilla of evidentiary support, but it does not demand a preponderance of the evidence. Wood v. Thompson, 246 F.3d 1026, 1029 (7th Cir. 2001).

The ALJ is required to articulate a minimal, but legitimate, justification for her decision to accept or reject specific evidence of a disability. Scheck v. Barnhart, 357 F.3d 697, 700 (7th Cir. 2004). The ALJ need not address every piece of evidence in her decision, but she cannot ignore a line of evidence that undermines the conclusions she made, and she must trace the path of her reasoning and connect the evidence to her findings and conclusions. Arnett v. Astrue, 676 F.3d 586, 592 (7th Cir. 2012); Clifford v.

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