Sanchez v. Commissioner of the Social Security Administration

CourtDistrict Court, E.D. Wisconsin
DecidedMarch 23, 2022
Docket2:21-cv-00290
StatusUnknown

This text of Sanchez v. Commissioner of the Social Security Administration (Sanchez v. Commissioner of the Social Security Administration) is published on Counsel Stack Legal Research, covering District Court, E.D. Wisconsin primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Sanchez v. Commissioner of the Social Security Administration, (E.D. Wis. 2022).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WISCONSIN JENNIFER MARIE SANCHEZ Plaintiff, v. Case No. 21-C-290 KILOLO KIJAKAZI, Acting Commissioner of the Social Security Administration Defendant. DECISION AND ORDER In May 2007, the Social Security Administration awarded disability benefits to plaintiff Jennifer Sanchez. The agency is required to periodically review a claimant’s entitlement to benefits to ensure that she is still disabled, 42 U.S.C. § 421(i); 20 C.F.R. § 416.994(a), and in January 2015 the agency found that plaintiff’s disability continued. In October 2018, however, the agency determined that plaintiff was no longer entitled to benefits. Plaintiff requested

review of this determination by an Administrative Law Judge (“ALJ”), but the ALJ concluded that the evidence demonstrated medical improvement such that plaintiff could perform a range of sedentary, unskilled work. Proceeding pro se, plaintiff seeks judicial review of the ALJ’s decision. I. LEGAL STANDARDS A. Disability Review Initial eligibility for disability benefits is determined by applying a five-step analysis, in which the ALJ considers whether: (1) the claimant is presently employed; (2) the claimant has a severe impairment or combination of impairments; (3) the claimant’s impairment meets or equals an impairment listed in the regulations (“the Listings”) as being so severe as to preclude substantial gainful activity; (4) the claimant’s residual functional capacity (“RFC”) leaves her unable to perform her past relevant work; and (5) the claimant is unable to perform any other jobs existing in significant numbers in the national economy. Butler v. Kijakazi, 4 F.4th 498, 501 (7th Cir. 2021).

As indicated above, there is a statutory requirement that, if a claimant is found disabled, her continued entitlement to benefits be reviewed periodically. 20 C.F.R. § 416.994(a). In conducting a disability review, the agency follows a seven-step process in determining whether a claimant is still disabled. 20 C.F.R. § 416.994(b)(5). Step 1. Does the claimant have an impairment or combination of impairments which meets or equals the severity of an impairment set forth in the Listings? If so, disability continues. Step 2. If not, has there been “medical improvement” in the claimant’s condition since the most recent decision in her favor, i.e., the “comparison point decision” or “CPD”? Medical

improvement is any decrease in the medical severity of the impairments present at the time of the most recent favorable decision that the claimant was disabled or continued to be disabled. 20 C.F.R. § 416.994(b)(1)(i). Step 3. If there has been medical improvement, does that improvement relate to the claimant’s ability to work? Step 4. If there has been no medical improvement (as determined at step 2) or if that improvement is not related to the claimant’s ability to work (as determined at step 3), disability continues. Step 5. If medical improvement relates to the claimant’s ability to do work, are the 2 claimant’s current impairments severe? Step 6. If the impairments are severe, will the claimant’s current residual functional capacity (“RFC”) permit her to perform her past work? If so, disability ends. Step 7. If the claimant cannot do past work, can she do other work given her current RFC, age, education, and work experience? If so, disability ends; if not, it continues.

B. Judicial Review The court will uphold an ALJ’s decision if he applied the correct legal standards and supported his decision with substantial evidence. Surprise v. Saul, 968 F.3d 658, 661 (7th Cir. 2020). Substantial evidence is not a high threshold: it means only such relevant evidence as a reasonable mind might accept as adequate to support a conclusion. Karr v. Saul, 989 F.3d 508, 511 (7th Cir. 2021). The reviewing court will not re-weigh the evidence, resolve debatable evidentiary conflicts, determine credibility, or substitute its judgment for the ALJ’s; rather, the court asks whether the ALJ’s decision reflects an adequate logical bridge from the evidence to the conclusions. Reynolds v. Kijakazi, 25 F.4th 470, 473 (7th Cir. 2022).

II. FACTS AND BACKGROUND A. Plaintiff’s Initial Application Plaintiff initially applied for disability benefits in February 2007, alleging an onset date of January 19, 2002. (Tr. at 184.) The record contains hospital records from February 2002, when plaintiff was 22 years old, indicating that plaintiff was seen for gait ataxia, nausea and decreased coordination of the left upper extremity, admitted for management of a suspected medullary mass, and subsequently underwent a craniectomy for biopsy and excision of the mass. Pathology revealed an intramedullary cavernoma. Physical therapy assisted with gait

3 training, and plaintiff reported marked decrease of symptoms in her left arm. (Tr. at 315-16.) On April 19, 2007, after she applied for benefits, the agency sent plaintiff for a consultative exam with Ward Jankus, M.D. Plaintiff complained of left-sided weakness, numbness, and left thigh pain, which she attributed to the February 2002 surgery and an assault occurring three months later. She had received limited treatment since then due to lack

of insurance. (Tr. at 333.) She also complained of bowel and bladder issues, as well as cognitive deficits. (Tr. at 334.) Dr. Jankus assessed history of brain surgery with residual left side symptoms and some cognitive changes, as well as bowel and bladder issues, and rule out left greater than right hip degenerative changes. (Tr. at 336.) Dr. Jankus noted that from a mobility standpoint plaintiff seemed fairly limited, and cognitively there seemed to be some suggestion of difficulty with short-term memory as well as computation and concentration issues. (Tr. at 337.) An x-ray revealed moderate to severe osteoarthritic changes in both hips. (Tr. at 338.) The agency granted plaintiff’s 2007 application. B. Disability Review

As required, the agency subsequently reviewed plaintiff’s condition to ensure that disability continued. (Tr. at 198-224.) Of significance here, on January 27, 2015, the agency continued plaintiff’s benefits, with a primary diagnosis of osteoarthrosis and allied disorders. (Tr. at 91, 94.) As part of that review, the agency sent plaintiff for psychological and neurological consultative evaluations (Tr. at 401-11), but benefits were continued based on the review of Mina Khorshidi, M.D., who found Listing 1.02A met based on hip degenerative joint disease (Tr. at 413). Dr. Khorshidi noted that plaintiff underwent left hip replacement in 2010, with plans for right hip replacement after she lost weight. Dr. Khorshidi found no significant medical improvement since the previous decision. (Tr. at 413.) The January 27, 2015, 4 determination constitutes the comparison point decision for purposes of this action. In July 2017, plaintiff underwent right total hip replacement surgery. (Tr. at 414-15, 431- 33.) She subsequently reported issues with incision healing (Tr. at 486-87, 500), but in physical therapy she demonstrated improved range of motion, strength, and mobility (Tr.

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Bluebook (online)
Sanchez v. Commissioner of the Social Security Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/sanchez-v-commissioner-of-the-social-security-administration-wied-2022.