McCarty v. Commissioner of Social Security

CourtDistrict Court, S.D. Illinois
DecidedSeptember 29, 2023
Docket3:22-cv-01852
StatusUnknown

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

Opinion

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

SARAH M.,1 ) ) Plaintiff, ) ) vs. ) Case No. 3:22-cv-1852-DWD ) COMMISSIONER OF SOCIAL ) SECURITY, ) ) Defendant. )

MEMORANDUM & ORDER DUGAN, District Judge: Under 42 U.S.C. § 405(g), Plaintiff seeks judicial review of the final agency decision of Defendant, which denied Plaintiff’s application for Disability Insurance Benefits (DIBs). For the reasons explained below, the Court AFFIRMS the final agency decision. I. Procedural History Plaintiff was born on September 17, 1979. She protectively applied for DIBs on April 15, 2015. Plaintiff initially alleged a disability onset date of November 1, 2012, but that date was later amended to June 30, 2013. Plaintiff’s date of last insured was December 31, 2017. The alleged disability was related to cervical radiculopathy, scoliosis, migraines, fibromyalgia, bone degeneration, nerve damage, sphincter dysfunction, chronic fatigue syndrome, anxiety, asthma, and severe memory loss. (Doc. 14-9, pg. 24). The claim was denied initially and on reconsideration. Plaintiff sought a hearing, which was held in October 2017 before an Administrative Law Judge (“ALJ”). In July 2018, Plaintiff received

1Plaintiff’s full name will not be used due to privacy concerns. an Unfavorable Decision. The Appeals Council denied review, so Plaintiff appealed to this Court. Before the Court could resolve the appeal, however, the parties agreed to a

remand of the case to the agency. A second hearing was held on October 1, 2020. On November 25, 2020, Plaintiff received another Unfavorable Decision. Plaintiff filed written exceptions to that Unfavorable Decision, which were rejected by the Appeals Council in June 2022. Plaintiff has now exhausted her administrative remedies. Accordingly, the most recent Unfavorable Decision is final and ripe for judicial review. II. General Legal Standards

To qualify for DIBs, a claimant must be disabled. To assess a disability, the ALJ employs a “five-step sequential evaluation process.” See 20 C.F.R. § 404.1520(a)(1), (2), (4). The ALJ asks whether: (1) the claimant is doing substantial gainful activity; (2) 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) the claimant has an impairment that meets or equals an impairment listed in the regulations and satisfies the duration requirements; (4) in view of the RFC and past relevant work, she can perform past relevant work; and (5) in view of the claimant’s RFC, age, education, and work experience, she can adjust to other work. See 20 C.F.R. § 404.1520(a)(4)-(g); 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 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). If the claimant has an impairment that meets the requirements of step 3 or is incapable of adjusting to other work under step 5, then she is disabled. See 20 C.F.R. § 404.1520(a)(4)(iii), (v). The claimant

has the burden of proof at steps 1 to 4. See Mandrell v. Kijakazi, 25 F.4th 514, 516 (7th Cir. 2022). At step 5, however, the burden shifts to Defendant to show that the claimant can adjust to other work existing in “a significant number of jobs…in the national economy.” See Young, 362 F.3d at 1000; accord Brace v. Saul, 970 F.3d 818, 820 (7th Cir. 2020). Impairments and related symptoms may cause physical and mental limitations that affect the ability to work. See 20 C.F.R. § 404.1545(a)(1). Steps 4 and 5 assess the most

a claimant can do at work despite those limitations. See 20 C.F.R. § 404.1545(a)(1); accord SSR 96-8p, 1996 WL 374184, *2; Clifford v. Apfel, 227 F.3d 863, 872-73 n. 7 (7th Cir. 2000). As such, a residual functional capacity (“RFC”), which the ALJ completes after step 3 but before steps 4 and 5, assesses the ability to perform sustained physical and mental activities in a work setting on a regular and continuing basis, i.e., for eight hours a day

and five days a week or an equivalent schedule. See Tenhove v. Colvin, 97 F. Supp. 2d 557, 568 (E.D. Wisc. 2013); SSR 96-8p, 1996 WL 374184, *2; accord Moore v. Colvin, 743 F.3d 1118, 1121 (7th Cir. 2014). An RFC must be based on the relevant medical and other evidence contained in the record. See 20 C.F.R. § 404.1545(a)(3); SSR 96-8p, 1996 WL 374184, *2-3, 5. In the RFC, the ALJ must identify the claimant’s functional limitations and assess

his work-related abilities on a function-by-function basis. See Tenhove, 97 F. Supp. 2d at 569; SSR 96-8p, 1996 WL 374184, *1, 3; accord Lechner v. Barnhart, 321 F. Supp. 2d 1015, 1036 (E.D. Wisc. 2004). The ALJ considers all impairments, including those that are nonsevere, and the claimant’s ability to meet physical, mental, sensory, and other requirements of work. See 20 C.F.R. § 404.1545(a)(2), (4); see also Alesia v. Astrue, 789 F. Supp. 2d 921, 933 (N.D. Ill. 2011) (“[T]he ALJ must consider the combined effect of all

impairments, ‘even those that would not be considered severe in isolation.’ “). “An impairment or combination of impairments is not severe if it does not significantly limit [the] physical or mental ability to do basic work activities.” 20 C.F.R. § 404.1522(a). And, importantly, while a claimant’s statements of pain or other symptoms are considered, they alone are not conclusive evidence of a disability. See 20 C.F.R. § 404.1529. As to physical abilities, the ALJ assesses the nature and extent of physical

limitations, then determines the RFC for work activity on a regular and continuing basis. See 20 C.F.R. § 404.1545(b). A limited ability to perform physical demands, such as sitting, standing, walking, lifting, carrying, pushing, pulling, reaching, handling, stooping, or crouching may reduce the ability to do “other work” at step 5.

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