United States District Court, N.D. Illinois, Eastern Division
MEMORANDUM OPINION AND ORDER
MARY M. ROWLAND, Magistrate Judge.
Plaintiff Emma McCaster filed this action seeking review of the final decision of Defendant Commissioner of Social Security denying her applications for Disability Insurance Benefits ("DIB") and Supplemental Security Income ("SSI") under the Social Security Act. 42 U.S.C. §§ 416(i), 1381a. The parties have consented to the jurisdiction of the United States Magistrate Judge, pursuant to 28 U.S.C. § 636(c). Plaintiff has filed a motion for summary judgment requesting the Court to reverse the Commissioner's decision. For the reasons stated below, the case is remanded for further proceedings consistent with this opinion.
I. THE FIVE-STEP SEQUENTIAL EVALUATION PROCESS
To recover DIB or SSI, a claimant must establish that he or she is disabled within the meaning of the Social Security Act. See Elder v. Astrue, 529 F.3d 408, 409-410 (7th Cir. 2008). A person is disabled if he or she is unable to perform "any substantial gainful activity by reason of any medically determinable physical or mental impairment which can be expected to result in death or which has lasted or can be expected to last for a continuous period of not less than 12 months." 20 C.F.R. § 416.905(a). In determining whether a claimant suffers from a disability, the ALJ conducts a standard five-step inquiry:
1. Is the claimant presently unemployed?
2. Does the claimant have a severe medically determinable physical or mental impairment that interferes with basic work-related activities and is expected to last at least twelve months?
3. Does the impairment meet or equal one of a list of specific impairments enumerated in the regulations?
4. Is the claimant unable to perform his or her former occupation?
5. Is the claimant unable to perform any other work?
20 C.F.R. §§ 416.909, 416.920; see Clifford v. Apfel, 227 F.3d 863, 868 (7th Cir. 2000). "An affirmative answer leads either to the next step, or, on Steps 3 and 5, to a finding that the claimant is disabled. A negative answer at any point, other than Step 3, ends the inquiry and leads to a determination that a claimant is not disabled." Zalewski v. Heckler, 760 F.2d 160, 162 n.2 (7th Cir. 1985). The claimant bears the burden of proof through Step 4, but at Step 5 the burden shifts to the Commissioner. Clifford, 227 F.3d at 868.
II. PROCEDURAL HISTORY
Emma McCaster applied for period of disability, DIB, and SSI on December 11, 2008, alleging that she became disabled on December 27, 2007. (R. at 9; Dkt. 20 at 1; Dkt. 27 at 1.) This application was denied initially on March 5, 2009 and, upon reconsideration, on September 16, 2009. (R. at 9, 43, 50.) Subsequently, on October 27, 2009, McCaster filed a timely request for a hearing. (R. at 9.) An Administrative Law Judge ("ALJ") conducted the hearing on July 12, 2010, during which McCaster appeared and testified without the assistance of counsel. (R. at 9, 20-38).)
On January 6, 2011, the ALJ denied McCaster's request for period of disability, DIB, and SSI. (R. at 16.) The ALJ initially determined that McCaster met the insured status requirements of the Social Security Act through December 31, 2012. (R. at 11.) The ALJ then engaged in the five-step sequential evaluation process, finding, at Step 1, that McCaster had not engaged in substantial gainful activity since December 27, 2007, the alleged onset date. ( Id. ) Then, at Step 2, the ALJ found that McCaster had the severe impairments of status post left ankle fracture, status post Achilles tendon repair surgery, and obesity. ( Id. ) At Step 3, the ALJ determined that McCaster did not have an impairment or combination of impairments that met or medically equaled one of the listings enumerated in the regulations. (R. at 12.)
The ALJ then assessed McCaster's residual functional capacity ("RFC"), determining that she had the RFC to perform light work, as defined in 20 C.F.R. §§ 404.1567(b), 416.967(b). (R. at 12.) The ALJ stated:
[McCaster had the] abilities ( sic ) to lift and carry up to 10 pounds frequently and 20 pounds occasionally, to sit for 6 hours in an 8-hour workday, and to stand and walk each for 6 hours in an 8-hour workday-except with the following additional limitations:
- Can never climb ladders; and
- Can only occasionally climb ramps and stairs, balance, stoop, crouch, kneel, and crawl.
( Id. ) At Step 4, the ALJ determined that McCaster was capable of performing her past relevant work as a phlebotomist. (R. at 15.) Accordingly, the ALJ concluded that McCaster was not disabled, as defined by the Social Security Act, from December 27, 2007 through the date of the decision. (R. at 16.)
On April 18, 2012, the Appeals Council denied McCaster's request for review. (R. at 1-5.) McCaster now seeks judicial review of the ALJ's decision, which stands as the final decision of the Commissioner. ( Id. ) See, e.g., Villano v. Astrue, 556 F.3d 558, 561-62 (7th Cir. 2009).
III. STANDARD OF REVIEW
Judicial review of the Commissioner's final decision is authorized by section 205(g) of the Social Security Act. See 42 U.S.C. § 405(g). In reviewing this decision, the Court may not engage in its own analysis of whether the plaintiff is severely impaired as defined by the Social Security Regulations. Young v. Barnhart, 362 F.3d 995, 1001 (7th Cir. 2004). Nor may it "reweigh evidence, resolve conflicts in the record, decide questions of credibility, or, in general, substitute [its] own judgment for that of the Commissioner." Id. The Court's task is "limited to determining whether the ALJ's factual findings are supported by substantial evidence." Id. (citing 42 U.S.C. § 405(g)). Evidence is considered substantial "if a reasonable person would accept it as adequate to support a conclusion." Indoranto v. Barnhart, 374 F.3d 470, 473 (7th Cir. 2004). "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). "In addition to relying on substantial evidence, the ALJ must also explain his analysis of the evidence with enough detail and clarity to permit meaningful appellate review." Briscoe ex rel. Taylor v. Barnhart, 425 F.3d 345, 351 (7th Cir. 2005).
Although this Court accords great deference to the ALJ's determination, it "must do more than merely rubber stamp the ALJ's decision." Scott v. Barnhart, 297 F.3d 589, 593 (7th Cir. 2002) (internal quotations and citation omitted). The Court must critically review the ALJ's decision to ensure that the ALJ has built an "accurate and logical bridge from the evidence to his conclusion." Young, 362 F.3d at 1002 (internal quotations and citation omitted). Where the Commissioner's decision "lacks evidentiary support or is so ...