United States District Court, S.D. Indiana, Indianapolis Division
ENTRY REVIEWING THE COMMISSIONER'S DECISION
JANE MAGNUS-STINSON, District Judge.
Plaintiff Valerie Philpott applied for disability insurance benefits from the Social Security Administration ("SSA") on July 1, 2010. After a series of administrative proceedings and appeals, including a hearing in July 2011 before Administrative Law Judge ("ALJ") James R. Norris, the ALJ determined that Ms. Philpott was not entitled to benefits. The Appeals Council subsequently vacated the ALJ's decision and remanded the case for a new hearing and decision. In April 2012, the ALJ held another hearing, and in May 2012, the ALJ determined that Ms. Philpott was not entitled to benefits. This time, the Appeals Council denied Ms. Philpott's request for a review of the ALJ's decision, rendering that decision the final decision of the Defendant, Commissioner of the SSA ("the Commissioner"), for the purposes of judicial review. See 20 C.F.R. § 404.981. Ms. Philpott then filed this action under 42 U.S.C. § 405(g), requesting that the Court review the Commissioner's denial.
STANDARD OF REVIEW
The Court's role in this action is limited to ensuring that the ALJ applied the correct legal standards and that substantial evidence exists for the ALJ's decision. Barnett v. Barnhart, 381 F.3d 664, 668 (7th Cir. 2004) (citation omitted). For the purpose of judicial review, "[s]ubstantial evidence is such relevant evidence as a reasonable mind might accept as adequate to support a conclusion." Id. (citation omitted) (internal quotation marks omitted). Because the ALJ "is in the best position to determine the credibility of witnesses, " Craft v. Astrue, 539 F.3d 668, 678 (7th Cir. 2008), this Court must afford the ALJ's credibility determination "considerable deference, " overturning it only if it is "patently wrong." Prochaska v. Barnhart, 454 F.3d 731, 738 (7th Cir. 2006) (citations omitted).
If the ALJ committed no legal error and substantial evidence exists to support the ALJ's decision, the Court must affirm the denial of benefits. Otherwise the Court will remand the matter back to the SSA for further consideration; only in rare cases can the Court actually order an award of benefits. See Briscoe v. Barnhart, 425 F.3d 345, 355 (7th Cir. 2005).
To evaluate a disability claim, an ALJ must use the following five-step inquiry:
(1) [is] the claimant... currently employed, (2) [does] the claimant ha[ve] a severe impairment, (3) [is] the claimant's impairment... one that the Commissioner considers conclusively disabling, (4) if the claimant does not have a conclusively disabling impairment, ... can she perform her past relevant work, and (5) is the claimant... capable of performing any work in the national economy[?]
Dixon v. Massanari, 270 F.3d 1171, 1176 (7th Cir. 2001) (citations omitted). After Step Three, but before Step Four, the ALJ must determine a claimant's residual functional capacity ("RFC"), which represents the claimant's physical and mental abilities considering all of the claimant's impairments. 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. See 20 C.F.R. § 416.920(e).
Medical records show that Ms. Philpott has suffered from various physical and mental impairments. The Court discusses this medical evidence in more detail below when necessary to address the issue raised by Ms. Philpott on appeal.
Ms. Philpott applied for disability insurance benefits, alleging that she has been disabled since January 1, 2004. [Filing No. 16-6 at 35.] She last met the insured status requirements of the Social Security Act on December 31, 2004, and at that time was forty-nine years old. [Filing No. 16-2 at 22.]
In his first decision, the ALJ determined at Step Four that Ms. Philpott was not entitled to disability insurance benefits. [Filing No. 16-3 at 9-20.] The Appeals Council granted Ms. Philpott's request for review and remanded the case back to the ALJ for reconsideration. [Filing No. 16-3 at 27.] On remand, the ALJ again determined that Ms. Philpott was not entitled to disability insurance benefits. [Filing No. 16-2 at 31.] The Appeals Council denied Ms. Philpott's request for review ...