MONTOOTH v. COLVIN

CourtDistrict Court, S.D. Indiana
DecidedNovember 27, 2024
Docket1:24-cv-00333
StatusUnknown

This text of MONTOOTH v. COLVIN (MONTOOTH v. COLVIN) 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
MONTOOTH v. COLVIN, (S.D. Ind. 2024).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA INDIANAPOLIS DIVISION

MIRANDA M., ) ) Plaintiff, ) ) v. ) No. 1:24-cv-00333-MPB-MKK ) MARTIN J. O'MALLEY, ) ) ) Defendant. )

REPORT & RECOMMENDATION

Plaintiff Miranda M.1 requests judicial review of the final decision of the Commissioner of the Social Security Administration ("Commissioner") denying her application for Title II Disability Insurance Benefits ("DIB"). On July 17, 2024, United States District Judge Matthew P. Brookman entered an Order referring this matter to the undersigned for a report and recommendation regarding the appropriate disposition pursuant to 28 U.S.C. § 636(b)(1)(B). (Dkt. 16). For the reasons set forth below, the undersigned recommends that the Commissioner's decision denying Plaintiff's application for benefits be AFFIRMED.

1 In an effort to protect the privacy interests of claimants for Social Security benefits, the Southern District of Indiana has adopted the recommendations put forth by the Court Administration and Case Management Committee of the Administrative Office of the United States Courts regarding the practice of using only the first name and last initial of any non-government parties in Social Security opinions. The undersigned has elected to implement that practice in this Order, in both the Order's body and the Order's caption. I. Procedural History Plaintiff filed her application for benefits on July 12, 2021, alleging disability beginning May 19, 2021. (Dkt. 10-5 at 13, R. 188). Her claim was initially denied on

January 10, 2022, (Dkt. 10-3 at 20, R. 87), then again upon reconsideration on March 28, 2022, (id. at 21, R. 88). Plaintiff requested a hearing, which occurred telephonically before ALJ Teresa Kroenecke on October 4, 2022. (Dkt. 10-2 at 38, R. 37). At the hearing, Plaintiff, who was represented by counsel, and Vocational Expert ("VE") Stephanie Archer testified. (Id. at 40, R. 39). In a written decision, the ALJ concluded Plaintiff had not been under a disability, as defined in the Social

Security Act, from May 19, 2021, through the date of the decision, July 27, 2023. (Id. at 25, R. 24). The Social Security Administration's ("SSA's") Appeals Council denied Plaintiff's request for review, finding Plaintiff failed to provide a basis for changing the ALJ's decision. (Id. at 2, R. 1). Plaintiff then filed for judicial review. See 42 U.S.C. § 405(g). II. Legal Standard To qualify for disability, a claimant must be disabled within the meaning of

the Social Security Act. 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 12 months." 42 U.S.C. § 423(d)(1)(A). To meet this definition, a claimant's impairments must be of such severity that she is not able to perform the work she previously engaged in and, 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. 42 U.S.C. § 423(d)(2)(A).

The SSA has implemented these statutory standards by, in part, prescribing a five-step sequential evaluation process for determining disability. 20 C.F.R. § 404.1520(a).2 The ALJ must consider whether: (1) the claimant is presently [un]employed; (2) the claimant has a severe impairment or combination of impairments; (3) the claimant's impairment meets or equals any impairment listed in the regulations as being so severe as to preclude substantial gainful activity; (4) the claimant's residual functional capacity leaves him unable to perform his past relevant work; and (5) the claimant is unable to perform any other work existing in significant numbers in the national economy.

Briscoe ex rel. Taylor v. Barnhart, 425 F.3d 345, 351–52 (7th Cir. 2005) (citation omitted). An affirmative answer to each step leads either to the next step or, at steps three and five, to a finding that the claimant is disabled. 20 C.F.R. § 404.1520(a)(4)(iii), (v); Briscoe, 425 F.3d at 352. "If a claimant satisfies steps one and two, but not three, then [s]he must satisfy step four." Knight v. Chater, 55 F.3d 309, 313 (7th Cir. 1995). "Once step four is satisfied, the burden shifts to the SSA to establish that the claimant is capable of performing work in the national economy."

2 The Code of Federal Regulations contains separate, parallel sections pertaining to disability benefits under the different titles of the Social Security Act, such as the one cited here that is applicable to DIB. Often, the parallel section pertaining to the other type of benefits—supplemental security income ("SSI")—is verbatim and makes no substantive legal distinction based on the benefit type. See 20 C.F.R. § 416.920(a). Because the statutory references for DIB and SSI claims are substantially similar, the undersigned may reference them interchangeably throughout this opinion. Id. (citations omitted); see also 20 C.F.R. § 404.1520. A negative answer at any point, other than step three, terminates the inquiry and leads to a determination that the claimant is not disabled.

After step three, but before step four, the ALJ must determine a claimant's residual functional capacity ("RFC") by evaluating "all limitations that arise from medically determinable impairments, even those that are not severe[.]" Villano v. Astrue, 556 F.3d 558, 563 (7th Cir. 2009) (citations omitted). The RFC is an assessment of what a claimant can do despite her limitations. Young v. Barnhart, 362 F.3d 995, 1000–01 (7th Cir. 2004) (citation omitted). In making this

assessment, the ALJ must consider all the relevant evidence in the record. Id. at 1001. The ALJ uses the RFC at step four to determine whether the claimant can perform her own past relevant work and if not, at Step Five to determine whether the claimant can perform other work in the national economy. See 20 C.F.R. § 404.1520(a)(4)(iv)–(v). The claimant bears the burden of proof through step four. Briscoe, 425 F.3d at 352 (citation omitted). If the first four steps are met, the burden shifts to the

Commissioner at step five. Id. (citation omitted). The Commissioner must then establish that the claimant—in light of her age, education, job experience, and RFC to work—is capable of performing other work and that such work exists in the national economy. 42 U.S.C.

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MONTOOTH v. COLVIN, Counsel Stack Legal Research, https://law.counselstack.com/opinion/montooth-v-colvin-insd-2024.