ST. CLAIR v. KIJAKAZI

CourtDistrict Court, S.D. Indiana
DecidedNovember 22, 2022
Docket4:22-cv-00021
StatusUnknown

This text of ST. CLAIR v. KIJAKAZI (ST. CLAIR 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
ST. CLAIR v. KIJAKAZI, (S.D. Ind. 2022).

Opinion

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF INDIANA NEW ALBANY DIVISION

ROBBIE S., ) ) Plaintiff, ) ) v. ) Case No. 4:22-cv-00021-TWP-KMB ) KILOLO KIJAKAZI, Acting Commissioner of the ) Social Security Administration, ) ) Defendant. )

ENTRY ON JUDICIAL REVIEW

Pro se Plaintiff Robbie S.1 requests judicial review of the final decision of the Commissioner of the Social Security Administration (the "SSA"), denying his application for Disability Insurance Benefits under the Social Security Act. For the following reasons, the Court affirms the decision of the Commissioner. I. PROCEDURAL BACKGROUND On September 2, 2020, Robbie S. filed an application for Disability Insurance Benefits, alleging a disability onset date of September 1, 2015. (Filing No. 4-8 at 2-6.) His application was initially denied on January 4, 2021, (Filing No. 4-5 at 8), and upon reconsideration on March 4, 2021, (Filing No. 4-5 at 14). Due to the coronavirus pandemic, Administrative Law Judge Stuart T. Janney (the "ALJ") conducted a telephone hearing on July 12, 2021. Robbie S., represented by counsel, and a vocational expert ("VE") participated and testified. (Filing No. 4-3 at 4-35.) During the hearing, Robbie S. amended his alleged onset date to April 14, 2018. (Filing No. 4-3 at 5-6.)

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. The ALJ issued a decision on August 3, 2021, concluding that Robbie S. was not entitled to benefits. (Filing No. 4-2 at 16-34.) The Appeals Council denied review on December 20, 2021. (Filing No. 4-2 at 4.) On January 13, 2022, Robbie S. requested that the SSA allow additional time to file a civil action. (Filing No. 4-2 at 3.) On February 23, 2022, Robbie S. filed this civil

action, asking the Court pursuant to 42 U.S.C. § 405(g) to review the final decision of the Commissioner.2 (Filing No. 1.) II. STANDARD OF REVIEW

"The Social Security Administration (SSA) provides benefits to individuals who cannot obtain work because of a physical or mental disability." Biestek v. Berryhill, 139 S. Ct. 1148, 1151 (2019). 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); Stephens v. Berryhill, 888 F.3d 323, 327 (7th Cir. 2018). To be found disabled, a claimant must demonstrate that his physical or mental limitations prevent him from doing not only his previous work but any other kind of gainful employment which exists in the national economy, considering his age, education, and work experience. 42 U.S.C. § 423(d)(2)(A). The Commissioner employs a five-step sequential analysis to determine whether a claimant is disabled. At step one, if the claimant is engaged in substantial gainful activity, he is not disabled despite his medical condition and other factors. 20 C.F.R. § 404.1520(a)(4)(i). At step two, if the claimant does not have a "severe" impairment that also meets the durational requirement, he is not disabled. 20 C.F.R. § 404.1520(a)(4)(ii). A severe impairment is one that "significantly limits [a

2 The Commissioner has not asserted that the civil filing was untimely. claimant's] physical or mental ability to do basic work activities." 20 C.F.R. § 404.1520(c). At step three, the Commissioner determines whether the claimant's impairment or combination of impairments meets or medically equals any impairment that appears in the Listing of Impairments, 20 C.F.R. Part 404, Subpart P, Appendix 1, and whether the impairment meets the twelve-month

duration requirement; if so, the claimant is deemed disabled. 20 C.F.R. § 404.1520(a)(4)(iii). If the claimant's impairments do not meet or medically equal one of the impairments on the Listing of Impairments, then his residual functional capacity will be assessed and used for the fourth and fifth steps. See 20 C.F.R. § 404.1520(a)(4)(iv)-(v). Residual functional capacity ("RFC") is the "maximum that a claimant can still do despite [his] mental and physical limitations." Craft v. Astrue, 539 F.3d 668, 675-76 (7th Cir. 2008) (citing 20 C.F.R. § 404.1545(a)(1); Social Security Ruling ("SSR") 96-8p (S.S.A. July 2, 1996), 1996 WL 374184). At step four, if the claimant can perform his past relevant work, he is not disabled. 20 C.F.R. § 404.1520(a)(4)(iv). At the fifth and final step, it must be determined whether the claimant can perform any other work, given his RFC and considering his age, education, and past work experience. 20 C.F.R. §

404.1520(a)(4)(v). The claimant is not disabled if he can perform any other work in the relevant economy. Id. The combined effect of all the impairments of the claimant shall be considered throughout the disability determination process. 42 U.S.C. § 423(d)(2)(B). The burden of proof is on the claimant for the first four steps; it then shifts to the Commissioner for the fifth step. Young v. Sec'y of Health & Human Servs., 957 F.2d 386, 389 (7th Cir. 1992). When an applicant appeals an adverse benefits decision, this Court's role is limited to ensuring that the ALJ applied the correct legal standards and that substantial evidence exists for the ALJ's decision. Stephens, 888 F.3d at 327. For the purpose of judicial review, "substantial evidence" is such relevant "evidence that 'a reasonable mind might accept as adequate to support a conclusion.'" Zoch v. Saul, 981 F.3d 597, 601 (7th Cir. 2020) (quoting Biestek, 139 S. Ct. at 1154). "Although this Court reviews the record as a whole, it cannot substitute its own judgment for that of the SSA by reevaluating the facts, or reweighing the evidence to decide whether a

claimant is in fact disabled." Stephens, 888 F.3d at 327. Reviewing courts also "do not decide questions of credibility, deferring instead to the ALJ's conclusions unless 'patently wrong.'" Zoch, 981 F.3d at 601 (quoting Summers v.

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Bluebook (online)
ST. CLAIR v. KIJAKAZI, Counsel Stack Legal Research, https://law.counselstack.com/opinion/st-clair-v-kijakazi-insd-2022.