Williams v. Commissioner of Social Security

CourtDistrict Court, S.D. Illinois
DecidedMarch 31, 2025
Docket3:23-cv-03741
StatusUnknown

This text of Williams v. Commissioner of Social Security (Williams 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
Williams v. Commissioner of Social Security, (S.D. Ill. 2025).

Opinion

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

A. L. WILLIAMS,1 ) ) Plaintiff, ) ) vs. ) Case No. 3:23-cv-3741-DWD ) COMMISSIONER OF SOCIAL ) SECURITY, ) ) Defendant. )

MEMORANDUM & ORDER DUGAN, District Judge: Under 42 U.S.C. §§ 405(g) and 1383(c)(3), Plaintiff seeks judicial review of the final agency decision of Defendant, which denied Plaintiff’s application for Supplemental Security Income (“SSI”). As stated below, the Court AFFIRMS the final agency decision. I. Procedural History Plaintiff was born on October 24, 1970. (Doc. 9-2, pg. 31). He protectively applied for SSI on December 30, 2020, alleging a disability onset date of March 23, 2019. (Docs. 9- 2, pg. 21; 18, pg. 6). The alleged disability related to, inter alia, degenerative joint disease and issues of the shoulder, wrist, and hand. (Docs. 9-2, pg. 28; 9-3, pg. 22; 18, pg. 7). The claim was initially denied on August 4, 2021, and it was again denied on reconsideration on January 5, 2022. (Doc. 9-2, pg. 21). Plaintiff sought a hearing, which was held by telephone with an Administrative Law Judge (“ALJ”) on February 27, 2023. (Doc. 9-2, pgs. 21, 41). On March 24, 2023, Plaintiff received an Unfavorable Decision. (Doc. 9-2, pgs.

1Plaintiff’s full name will not be used due to privacy concerns. 18-33). The Appeals Council denied review. (Doc. 9-2, pgs. 2-7). Plaintiff has exhausted his administrative remedies, so the ALJ’s final decision is ripe for a judicial review. II. Generally Applicable Legal Standards

A claimant must be disabled in order to receive SSI. To assess a disability, the ALJ employs a “five-step sequential evaluation process.” See 20 C.F.R. § 416.920(a)(1), (4). The ALJ asks whether the claimant: (1) is doing substantial gainful activity; (2) 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) has an impairment that meets or equals an impairment listed in the regulations and satisfies the duration requirements; (4) in view of his residual functional capacity (“RFC”) and past relevant work, can perform past relevant work, which is work done within the past five years that was substantial gainful activity and lasted long enough for him to learn how to do it; and (5) in view of his RFC, age, education, and work

experience, he can adjust to other work. See id. §§ 416.920(a)(4)-(g), 416.960(b)(1)(i). 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. 20 C.F.R. § 416.920(a)(4)(i), (ii), (iv), (v). If the claimant has an impairment

meeting the requirements of step 3 or is incapable of adjusting to other work under step 5, then he is disabled. See id. § 416.920(a)(4)(iii), (v). Plaintiff 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, the burden shifts to Defendant to show the claimant can adjust to other work existing in a significant number of jobs in the national economy. Brace v. Saul, 970 F.3d 818, 820 (7th Cir. 2020). Impairments and related symptoms, such as pain, may cause physical and mental

limitations that affect the ability of a claimant to work. See 20 C.F.R. § 416.945(a)(1). Steps 4 and 5 assess the most a claimant can do at work, despite those limitations. See id. § 416.945(a)(1); accord SSR 96-8p, 1996 WL 374184, *2; Clifford v. Apfel, 227 F.3d 863, 872- 73 n. 7 (7th Cir. 2000). Accordingly, an RFC, which the ALJ completes after step 3 but before steps 4 and 5, assesses the ability of the claimant 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. 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 of record. See 20 C.F.R. § 416.945(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. 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). When doing so, 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. 20 C.F.R. § 416.945(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. § 416.922(a). And, importantly, while a claimant’s statements of pain or other symptoms are considered, they alone do not constitute conclusive evidence of a disability. 20 C.F.R. § 416.929(a).

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. § 416.945(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 past and other work at step 5. Id.; see also SSR 96- 8p, 1996 WL 374184, *5-6. After identifying a claimant’s functional limitations and

assessing his work abilities on a function-by-function basis, the RFC may be expressed by exertional category, such as “light” or “sedentary.”2 Tenhove, 97 F. Supp. 2d at 569; accord Lechner, 321 F. Supp. 2d at 1036; SSR 96-8p, 1996 WL 374184, *3. In order to do a full range of work contemplated by an exertional category, the claimant must be able to perform substantially all of the functions at that level. See SSR 96-8p, 1996 WL 374184, *3.

Further, in the RFC, the ALJ must address medical source opinions. See SSR 96-8p, 1996 WL 374184, *7.

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Williams v. Commissioner of Social Security, Counsel Stack Legal Research, https://law.counselstack.com/opinion/williams-v-commissioner-of-social-security-ilsd-2025.