United States District Court, N.D. Indiana, Hammond Division
KEAREN L. BAUGH, Plaintiff,
CAROLYN W. COLVIN, Acting Commissioner of Social Security, Defendant.
OPINION AND ORDER
S. VAN BOKKELEN UNITED STATES DISTRICT JUDGE
Kearen L. Baugh seeks judicial review of the Acting Social
Security Commissioner's decision denying her claim for
disability insurance benefits. She asks this Court to reverse
the Commissioner's final decision or to remand this cause
for further proceedings. For the reasons below, the Court
Overview of the case
was 40 years old at the time of the alleged disability onset
date of February 15, 2011. She claims she became disabled as
a result of severe headaches, dizziness, neck pain, back
pain, and other pathologies. The Administrative Law Judge
(ALJ) found Plaintiff had the following severe impairments:
obesity, degenerative disc disease of the cervical spine,
migraines, and occipital neuralgia. Yet the ALJ found
Plaintiff does not have an impairment or combination of
impairments that meets or medically equals the severity of
one of the listed impairments in 20 C.F.R § 404.1520(d).
Moreover, the ALJ found Plaintiff has the residual functional
capacity to perform sedentary work, with some restrictions.
Standard of review
Court has authority to review the Commissioner's decision
under 42 USC § 405(g). The Court must ensure that the
ALJ has built an “accurate and logical bridge”
from evidence to conclusion. Thomas v. Colvin, 745
F.3d 802, 806 (7th Cir. 2014). The Court will uphold
decisions that apply the correct legal standard and are
supported by substantial evidence. Briscoe ex rel. Taylor
v. Barnhart, 425 F.3d 345, 351 (7th Cir. 2005).
Commissioner follows a five-step inquiry in evaluating claims
for disability benefits under the Social Security Act:
(1) whether the claimant is currently employed; (2) whether
the claimant has a severe impairment; (3) whether the
claimant's impairment is one that the Commissioner
considers conclusively disabling; (4) if the claimant does
not have a conclusively disabling impairment, whether he can
perform his past relevant work; and (5) whether the claimant
is capable of performing any work in the national economy.
Kastner v. Astrue, 697 F.3d 642, 646 (7th Cir.
claimant bears the burden of proof at every step except step
five. Clifford v. Apfel, 227 F.3d 863, 868 (7th Cir.
argues the ALJ committed three errors: (1) she failed to
account properly for Plaintiff's migraines in the
analysis of Plaintiff's residual functional capacity; (2)
she failed to account properly for occipital neuralgia
limitations in the assessment of Plaintiff's residual
functional capacity; and (3) she improperly relied on the
vocational expert's testimony as substantial evidence.
The ALJ erred by failing to build a logical bridge from
the evidence of Plaintiff's migraines to the ALJ's