United States District Court, Northern District of Illinois, Eastern Division
MEMORANDUM OPINION AND ORDER
HON. MARIA VALDEZ, United States Magistrate Judge.
Plaintiff Jean Christopher (“Plaintiff”) filed this action pursuant to 42 U.S.C. § 405(g), seeking review of the final decision of the Commissioner of Social Security (“the Commissioner”), which denied her claim for Social Security Disability Insurance (“SSDI”) benefits and Supplemental Security Income (“SSI”). The parties have consented to the jurisdiction of this Court pursuant to 28 U.S.C. § 636(c). For the following reasons, the Court denies Plaintiff’s Motion for Summary Judgment, [Doc. No. 15], and grants the Commissioner’s Motion for Summary Judgment, [Doc. No. 20].
I. PROCEDURAL AND FACTUAL HISTORY
Since 2007, Plaintiff has had difficulty with balancing, seeing, remembering, and concentrating. Unfortunately, by 2008, these problems worsened, and Plaintiff found herself unable to continue working. She thus filed a Title II application for SSDI benefits and a Title XVI application for SSI benefits, alleging a disability onset date of February 15, 2008. Her application was denied initially and upon reconsideration. Accordingly, Plaintiff requested and received a hearing before an Administrative Law Judge (“ALJ”), who found that she was not disabled at Step Four of the Social Security Administration’s sequential analysis.
At the hearing, the ALJ found that Plaintiff suffered from the following severe impairments: semicircular canal dehiscence; vestibular migraine, and degenerative disc disease of the cervical spine. After determining that Plaintiff did not meet any listed impairment, the ALJ then calculated Plaintiff’s Residual Functional Capacity (“RFC”) and found that she could perform light work with the following exceptions: she should only occasionally climb ramps and stairs, and never climb ropes, ladders, or scaffolds; she should only occasionally balance, stoop, kneel, crouch, and crawl; and she must avoid any more than occasional exposure to extreme cold and hazards, such as moving machinery or unprotected heights.
The ALJ then consulted with a Vocational Expert (“VE”) to determine if Plaintiff could perform her past relevant work or any jobs in the national economy. On the basis of her RFC assessment and the VE’s testimony, the ALJ concluded that Plaintiff could perform her past relevant work as a bartender. Accordingly, ALJ found that Plaintiff was not disabled under the Social Security Act.
STANDARD OF REVIEW
I. ALJ LEGAL STANDARD
Under the Social Security Act, a person is disabled if she is unable “to engage in 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 twelve months.” 42 U.S.C. § 423(d)(1)(a). In order to determine whether a claimant is disabled, the ALJ conducts a five-step analysis and considers the following in order: (1) Is the claimant presently unemployed? (2) Does the claimant have a severe impairment? (3) Does the impairment meet or medically equal one of a list of specific impairments enumerated in the regulations? (4) Is the claimant unable to perform her former occupation? and (5) Is the claimant unable to perform any other work? 20 C.F.R. § 416.920(a)(4).
An affirmative answer at either step 3 or step 5 leads to a finding that the claimant is disabled. Young v. Sec’y of Health & Human Servs., 957 F.2d 386, 389 (7th Cir. 1992). A negative answer at any step, other than at step 3, precludes a finding of disability. Id. The claimant bears the burden of proof at steps 1–4. Id. Once the claimant shows an inability to perform past work, the burden then shifts to the Commissioner to show the claimant’s ability to engage in other work existing in significant numbers in the national economy. Id.
II. JUDICIAL REVIEW
Judicial review of the ALJ’s decision is limited to determining whether the ALJ’s findings are supported by substantial evidence or based upon legal error. Clifford v. Apfel, 227 F.3d 863, 869 (7th Cir. 2000); Stevenson v. Chater, 105 F.3d 1151, 1153 (7th Cir. 1997). Substantial evidence is “such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.” Richardson v. Perales, 402 U.S. 389, 401 (1971); Skinner v. Astrue, 478 F.3d 836, 841 (7th Cir. 2007). Under this standard, the ALJ is not required to address “every piece of evidence or testimony in the record, [but] the ALJ’s analysis must provide some glimpse into the reasoning behind her decision to deny benefits.” Zurawski v. Halter, 245 F.3d 881, 889 (7th Cir. 2001). Rather, the ALJ must simply “build an accurate and logical bridge from the evidence to his conclusion, ” Clifford, 227 F.3d at 872, and minimally articulate the “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).
In reviewing an ALJ’s decision, a court may not substitute its judgment for that of the Commissioner by reevaluating facts, reweighing evidence, resolving conflicts in evidence, or deciding questions of credibility. Skinner, 478 F.3d at 841. Thus, where conflicting evidence would allow reasonable minds to differ, the court must defer to ...