PRATT v. KIJAKAZI

CourtDistrict Court, S.D. Indiana
DecidedMay 12, 2023
Docket2:22-cv-00261
StatusUnknown

This text of PRATT v. KIJAKAZI (PRATT 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
PRATT v. KIJAKAZI, (S.D. Ind. 2023).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA TERRE HAUTE DIVISION

Elise P.,1 ) ) Plaintiff, ) ) v. ) No. 2:22-cv-261-JPH-MJD ) KILOLO KIJAKAZI, Acting Commissioner of ) the Social Security Administration, ) ) Defendant. )

REPORT AND RECOMMENDATION Claimant Elise P. requests judicial review of the final decision of the Acting Commissioner of the Social Security Administration ("Commissioner") denying her application for Disability Insurance Benefits ("DIB") under Title II of the Social Security Act ("the Act"). See 42 U.S.C. § 423(d). Judge James P. Hanlon has designated the undersigned Magistrate Judge to issue a report and recommendation pursuant to 28 U.S.C. § 636(b)(1)(B). [Dkt. 11.] For the reasons set forth below, the Magistrate Judge RECOMMENDS that the Court REVERSE and REMAND the decision of the Commissioner.

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 has opted to use only the first names and last initials of non-governmental parties in its Social Security judicial review opinions. I. Background Claimant applied for DIB in July 2020, alleging an onset of disability as of June 5, 2020. [Dkt. 5-5 at 2.] Claimant's application was denied initially and upon reconsideration, and a hearing was held before Administrative Law Judge Gregory Moldafsky ("ALJ") on September

14, 2021. [Dkt. 5-2 at 45.] On November 26, 2021, ALJ Moldafsky issued his determination that Claimant was not disabled. Id. at 16. The Appeals Council then denied Claimant's request for review on April 26, 2022. Id. at 2. Claimant timely filed her Complaint on June 29, 2022, seeking judicial review of the ALJ's decision. [Dkt. 1.] II. Legal Standards To be eligible for benefits, a claimant must have a disability pursuant to 42 U.S.C. § 423. Disability is defined as the "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 12 months." 42 U.S.C. § 423(d)(1)(A). To determine whether a claimant is disabled, the

Commissioner, as represented by the ALJ, employs a sequential, five-step analysis: (1) if the claimant is engaged in substantial gainful activity, she is not disabled; (2) if the claimant does not have a "severe" impairment, one that significantly limits her ability to perform basic work activities, she is not disabled; (3) if the claimant's impairment or combination of impairments meets or medically equals any impairment appearing in the Listing of Impairments, 20 C.F.R. pt. 404, subpart P, App. 1, the claimant is disabled; (4) if the claimant is not found to be disabled at step three, and is able to perform her past relevant work, she is not disabled; and (5) if the claimant is not found to be disabled at step three, cannot perform her past relevant work, but can perform certain other available work, she is not disabled. 20 C.F.R. § 404.1520. Before 2 continuing to step four, the ALJ must assess the claimant's residual functional capacity ("RFC") by "incorporat[ing] all of the claimant's limitations supported by the medical record." Crump v. Saul, 932 F.3d 567, 570 (7th Cir. 2019). In reviewing Claimant's appeal, the Court will reverse only "if the ALJ based the denial

of benefits on incorrect legal standards or less than substantial evidence." Martin v. Saul, 950 F.3d 369, 373 (7th Cir. 2020). Thus, an ALJ's decision "will be upheld if supported by substantial evidence," which means "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion." Jozefyk v. Berryhill, 923 F.3d 492, 496 (7th Cir. 2019). An ALJ need not address every piece of evidence but must provide a "logical bridge" between the evidence and his conclusions. Varga v. Colvin, 794 F.3d 809, 813 (7th Cir. 2015). This Court may not reweigh the evidence, resolve conflicts, decide questions of credibility, or substitute its judgment for that of the ALJ. Burmester v. Berryhill, 920 F.3d 507, 510 (7th Cir. 2019). Where substantial evidence supports the ALJ's disability determination, the Court must affirm the decision even if "reasonable minds could differ" on whether Claimant is disabled. Id.

III. ALJ Decision The ALJ first determined that Claimant had not engaged in substantial gainful activity since the alleged onset date of June 5, 2020. [Dkt. 5-2 at 18.] At step two, the ALJ found that Claimant had the following severe impairments: "lumbar degenerative disc disease with sacroiliac dysfunction and radiculopathy, complex regional pain syndrome (CRPS), and migraine headaches." Id. At step three, the ALJ found that Claimant's impairments did not meet or equal a listed impairment during the relevant time period. Id. at 19. The ALJ then found that, during the relevant time period, Claimant had the residual functional capacity ("RFC")

3 to perform light work as defined in 20 CFR 404.1567(b), except she requires the option to sit and stand option that would permit 4 hours of standing and walking in 8-hour workday; occasional operation of foot controls with right lower extremity; occasionally climb ramps and stairs; never climb ladders, ropes, and scaffolds; occasionally stoop, balance, kneel, and crouch; never crawl; occasional exposure to extreme cold and extreme heat; and never work at unprotected heights.

Id. at 20 (footnote omitted). At step four, the ALJ found that Claimant was not able to perform her past relevant work. Id. at 24. At step five, the ALJ, relying on testimony from a vocational expert ("VE"), determined that Claimant was able to perform jobs that exist in significant numbers in the national economy, such as bench assembler, electronics worker, and electrical assembler. Id. at 26. Accordingly, the ALJ concluded that Claimant was not disabled. Id. IV. Discussion Claimant raises numerous issues in her brief. Each of the issues will be addressed, as appropriate, below. A. ALJ's Consideration of CRPS Symptoms Claimant alleges that the symptoms caused by complex regional pain syndrome ("CRPS") in her right leg, along with symptoms from lumbar degenerative disc disease (specifically neuropathy) and migraine headaches, render her disabled. The ALJ found each of these conditions to be a severe impairment and acknowledged that Claimant alleged that she suffered from disabling symptoms caused by them. See [Dkt. 5-2 at 21]. In his decision, the ALJ recognized his obligation to evaluate Claimant's subjective symptoms pursuant to 20 C.F.R.

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Bluebook (online)
PRATT v. KIJAKAZI, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pratt-v-kijakazi-insd-2023.