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Snider v. Commissioner of Social Security

United States District Court, N.D. Indiana, South Bend Division

September 12, 2019

DAVID E. SNIDER Plaintiff,


          Michael G. Gotsch, Sr. United States Magistrate Judge

         Plaintiff, David E. Snider (“Snider”) filed his complaint in this Court seeking reversal of the Social Security Commissioner's final decision to deny his application for Disability Insurance Benefits (“DIB”) and Supplemental Security Income (“SSI”) under Titles II and XVI of the Social Security Act. This Court may enter a ruling in this matter based on the parties' consent pursuant to 28 U.S.C. § 636(b)(1)(B) and 42 U.S.C. § 405(g). For the reasons discussed below, the Court reverses and remands the decision of the Commissioner of the Social Security Administration (“SSA”).

         I. Overview of the Case

         Snider alleges an onset of disability on August 30, 2013, based on limitations arising from permanent nerve damage in his right arm, chronic back pain, lumbar degenerative disc disease, spina bifida, bilateral carpal tunnel, diabetes, chronic ankle pain, poor memory and balance issues following a stroke, vascular dementia, cervicalgia/cervicogenic headaches, and cubital tunnel syndrome. Snider was 50 years old on the alleged onset date. Snider completed high school and worked as a shipping and receiving clerk and a tractor trailer truck driver before the alleged onset date.

         Snider's applications for DIB and SSI on December 19, 2014, were denied initially and upon reconsideration. Following a March 9, 2017, hearing, the Administrative Law Judge (“ALJ”) issued a decision on April 17, 2017, affirming the SSA's denial of benefits. The ALJ found that Snider is not able to perform any past relevant work. [DE 10 at 54- 55]. The ALJ reached this conclusion after finding that Snider has (1) moderate limitations in understanding, remembering, or applying information; interacting with others; concentrating, persisting, or maintaining pace; and adapting or managing himself and (2) the residual functional capacity (“RFC”) to perform light work as defined by the Social Security regulations[1] with some limitations. [Id. at 48-49]. The ALJ further found, based upon the testimony of the vocational expert, that Snider can to meet the requirements for employment as a bench assembler, electronics worker, and production assembler as those jobs are defined by the Dictionary of Occupational Titles. [Id. at 55]. Accordingly, the ALJ denied Snider's claims for benefits.

         On February 7, 2018, the Appeals Council denied Snider's request for review, making the ALJ's decision the final decision of the Commissioner.

         II. Disability Standard

         In order to qualify for DIB or SSI, a claimant must be “disabled” under the Social Security Act (“Act”). A person is disabled under the Act if “he or she has an inability to engage in any substantial gainful activity by reason of a medically determinable physical or mental impairment which can be expected to last for a continuous period of not less than twelve months.” 42 U.S.C. § 423(d)(1)(A).

         The Commissioner's five-step inquiry in evaluating claims for disability benefits under the Act includes determinations as to: (1) whether the claimant is doing substantial gainful activity (“SGA”); (2) whether the claimant's impairments are severe; (3) whether any of the claimant's impairments, alone or in combination, meet or equal one of the Listings in Appendix 1 to Subpart P of Part 404; (4) whether the claimant can perform her past relevant work based upon her RFC; and (5) whether the claimant is capable of making an adjustment to other work. 20 C.F.R. § 404.1520; see also Kastner v. Astrue, 697 F.3d 642, 646 (7th Cir. 2012). The claimant bears the burden of proof at every step except Step Five. Clifford v. Apfel, 227 F.3d 863, 868 (7th Cir. 2000).

         III. Standard of Review

         On judicial review, the Act requires that the Court accept the Commissioner's factual findings as conclusive if supported by substantial evidence. 42 U.S.C. § 405(g); Clifford, 227 F.3d at 869. 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. Briscoe v. Barnhart, 425 F.3d 345, 351 (7th Cir. 2005). Substantial evidence must be “more than a scintilla but may be less than a preponderance.” Skinner v. Astrue, 478 F.3d 836, 841 (7th Cir. 2007). Thus, substantial evidence is simply “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971); Kepple v. Massanari, 268 F.3d 513, 516 (7th Cir. 2001).

         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. Boiles v. Barnhart, 395 F.3d 421, 425 (7th Cir. 2005). Thus, the question upon judicial review 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). The ALJ must build a logical bridge from the evidence to his conclusion and a reviewing court is not to substitute its own opinion for that of the ALJ, or to re-weigh the evidence. Haynes v. Barnhart, 416 F.3d 621, 626 (7th Cir. 2005). Even if an ALJ commits a legal or factual error, the error does not warrant remand unless it is harmful. Parker v. Astrue, 597 F.3d 920, 924 (7th Cir. 2010).

         Minimally, an ALJ must articulate his analysis of the evidence to allow the reviewing court to trace the path of his reasoning and to be assured that the ALJ considered the important evidence. Scott v. Barnhart, 297 F.3d 589, 595 (7th Cir. 2005). In reaching his decision, an ALJ must “consider all relevant medical evidence and cannot simply cherry-pick facts that support a finding of non-disability while ignoring evidence that points to a disability finding.” Denton v. Astrue, 596 F.3d 419, 425 (7th Cir. 2010). However, the ALJ need not specifically address every piece of evidence in the record to present the requisite “logical bridge” from the evidence to his conclusions. O'Connor-Spinner v. Astrue, 627 F.3d 614, 618 (7th Cir. 2010). The ALJ must simply provide a glimpse into the reasoning behind his analysis and the decision to deny benefits. Zurawski v. Halter, 245 F.3d 881, 889 (7th Cir. 2001).

         IV. Analysis

         A. ...

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