United States District Court, N.D. Indiana, South Bend Division
CHRISTOPHER A. NUECHTERLEIN, Magistrate Judge.
On April 9, 2014, Plaintiff Johnnie Coats ("Coats") filed his complaint in this Court seeking reversal of the Commissioner's final decision denying his application Supplemental Security Income ("SSI") and Disability Insurance Benefits ("DIB"). On August 6, 2014, Coats filed his Memorandum Of Law In Support Of A Social Security Appeal. [Doc. No. 15]. On October 30, 2014, Defendant Commissioner of Social Security ("Commissioner") filed a response, asking the Court to affirm the Administrative Law Judge's ("ALJ") decision denying Coats's applications for SSI and DIB. Coats filed a reply on November 13, 2014. This Court may enter a ruling in this matter based on the parties consent, 28 U.S.C. § 636(c), and 42 U.S.C. § 405(g).
I. RELEVANT BACKGROUND
On July 12, 2011, Coats filed applications for DIB and SSI alleging an onset date of January 15, 2011, due to a neck injury. After the SSA denied Coats's applications initially and upon reconsideration, an ALJ held a hearing regarding Coats's applications on January 3, 2013.
Coats was born on January 12, 1961, making him 50 years old at the alleged onset date. Coats completed the eleventh grade but did not obtain a GED. He lives with his girlfriend and her son. Before the alleged onset date, Coats worked as a furnace operator, grinder, temporary worker, and wire cutter. At his hearing before the ALJ, Coats testified that he broke his neck while intoxicated and attempting to retrieve his spare key from a window ledge to unlock the door to his house. Coats provided medical evidence, including records of doctor visits and treatment for neck pain, from the date of the injury through the date of the hearing.
More specifically, Coats provided the ALJ with the medical opinions and treatment notes from Dr. Roman Filipowicz, his treating neurosurgeon, and an RFC analysis by Dr. Ruiz, a State agency reviewing physician. Dr. Filipowicz's notes show that Coats was admitted to the hospital after his fall for a fracture of the cervical spine. Coats underwent stabilization surgery on January 26, 2011, and was instructed to wear a neck brace until told otherwise. In July 2011, Dr. Filipowicz referred Coats to the Center for Pain Control after Coats was kicked out of the physical therapy program. On September 22, 2011, Dr. Ruiz performed a physical RFC assessment as part of Coats's disability application process. Dr. Ruiz's RFC assessment projected that by January 15, 2012, twelve months after the alleged onset date, Coats would be able to perform light work. Treatment notes from the Center for Pain Control on January 13, 2012, reported findings consistent with a December 30, 2011, examination that showed guarded walking and guarded performance of other activities. Later treatment notes in February 2012, from the Center for Pain Control showed hypersensitivity and signs of nerve inflammation. In August of 2012, Dr. Filipowicz wrote a letter opining that Coats was incapable of physical labor.
After the hearing, the ALJ issued a written decision reflecting the following findings based on the five-step disability evaluation prescribed in the Social Security Administration's ("SSA's") regulations. At Step One, the ALJ found that Coats had not engaged in substantial gainful activity since January 15, 2011, the alleged onset date. At Step Two, the ALJ found that the residual effects of a neck fracture were a severe impairment. At Step Three, the ALJ found that Coats's impairments did not meet or medically equal the severity of a listed impairment. The ALJ also found that Coats had the residual functional capacity to perform light work with the following limitations: lift and carry up to 20 pounds occasionally and 10 pounds frequently; not limited in the amount of time that he is able to sit, stand, or walk throughout an eight hour workday but required a cane while walking; could perform no more than occasional balancing, stooping, kneeling, crouching, crawling, and climbing of ramps or stairs; could not climb ladders, ropes, or scaffolds; limited in the ability to rotate, flex, or extended his neck; able to perform bilateral overhead reaching occasionally; could not tolerate concentrated exposure to extreme cold; could not drive, operate moving machinery, work at unprotected heights, around exposed flames, or around large, unguarded bodies of water; or tolerate exposure to unguarded, hazardous machinery. At Step Four, the ALJ found that Coats was unable to perform any past relevant work. At Step Five, the ALJ considered Coats's, education, work experience, and residual functional capacity, from which he determined that jobs existed in the national economy that Coats could perform, such as an encapsulator or school bus monitor.
Based on these findings, the ALJ determined that Coats had not been disabled from January 15, 2011, which was reflected in his written decision issued on January 24, 2013. Coats requested that the Appeals Council review the decision of the ALJ and on February 7, 2014, the Appeals Council denied the request. Thus, the ALJ's decision became the final decision of the Commissioner for the purposes of judicial review.
A. Standard of Review
The Social Security Act authorizes judicial review of the final decision of the agency and indicates that the Commissioner's factual findings must be accepted as conclusive if supported by substantial evidence. 42 U.S.C. § 405(g). Thus, a court reviewing the findings of an ALJ will reverse only if the findings are not supported by substantial evidence or if the ALJ has applied an erroneous legal standard. See Briscoe v. Barnhart, 425 F.3d 345, 351 (7th Cir. 2005). Substantial evidence is more than a mere scintilla but may be less than the weight of the evidence. Scheck v. Barnhart, 357 F.3d 697, 699 (7th Cir. 2004) (citations omitted). Thus, substantial evidence is simply the relevant evidence needed for a reasonable mind to accept as adequate support for a conclusion. Kepple v. Massanari, 268 F.3d 513, 516 (7th Cir. 2001) (citations omitted).
A court reviews the entire administrative record but does not reconsider facts, re-weigh the evidence, resolve conflicts in evidence, decide questions of credibility, or substitute its judgment for that of the ALJ. See Boiles v. Barnhart, 395 F.3d 421, 425 (7th Cir. 2005). Thus, the question upon judicial review of an ALJ's finding that a claimant is not disabled within the meaning of the Social Security Act is not whether the claimant is, in fact, disabled, but whether the ALJ "uses the correct legal standards and the decision is supported by substantial evidence." Roddy v. Astrue, 705 F.3d 631, 636 (7th Cir. 2013) (citations omitted). "[I]f the Commissioner commits an error of law, " the Court may reverse the decision "without regard to the volume of evidence in support of the factual findings." White v. Apfel, 167 F.3d 369, 373 (7th Cir. 1999) (citation omitted).
At a minimum, an ALJ must articulate his analysis of the evidence in order to allow the reviewing court to trace the path of his reasoning and to be assured that the ALJ considered the important evidence. See Scott v. Barnhart, 297 F.3d 589, 595 (7th Cir. 2002). An ALJ must "build an accurate and logical bridge from the evidence to [the] conclusion so that [the court] may assess the validity of the agency's final decision and afford [a claimant] meaningful review." Giles v. Astrue, 483 F.3d 483, 487 (7th Cir. 2007) (quoting Scott, 297 F.3d at 595) (internal quotation marks omitted). Although the ALJ is not required to specifically address every piece of evidence in the record, there must be a "logical bridge" from the evidence to the ALJ's conclusions. ...