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Heredia v. Colvin

United States District Court, N.D. Illinois, Eastern Division

June 18, 2015

ORALIA HEREDIA, Plaintiff,
v.
CAROLYN COLVIN, Commissioner of Social Security, Defendant.

MEMORANDUM OPINION AND ORDER

MANISH S. SHAH, District Judge.

Oralia Heredia has multiple physical and psychological impairments. She applied for Social Security Disability Insurance benefits, but her application was denied. She requested a hearing, after which an Administrative Law Judge found that she had several severe impairments. Nonetheless, the ALJ found that she could perform sedentary jobs that existed in the national economy. Accordingly, the ALJ found that Heredia was not disabled. Heredia filed this suit, contending that the ALJ's decision was not supported by substantial evidence and is contrary to law. For the reasons below, the ALJ's decision is reversed and the case is remanded to the Commissioner of Social Security.

I. Legal Standards

A. Determination of Disability

Under the Social Security Act, a person is disabled if she is unable "to engage in any substantial gainful activity by reason of a 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. §§ 416(i)(1), 423(d)(1)(A). The Social Security Administration evaluates disability claims in five steps, considering whether the claimant:

1. is currently performing substantial gainful activity (if so, the claimant is not disabled);
2. has a severe impairment or combination of impairments (if not, the claimant is not disabled);
3. has an impairment that is equal to an impairment specifically listed in the regulations (if so, the claimant is disabled);
4. can perform her past relevant work (if so, the claimant is not disabled); and
5. can perform other work that exists in the national economy (if so, the claimant is not disabled).

20 C.F.R. §§ 404.1512(f); 404.1520(a)(4). To perform steps 4 and 5, the Administration determines the claimant's "residual functioning capacity, " which is "what an individual can still do despite his or her limitations." Murphy v. Colvin, 759 F.3d 811, 817 (7th Cir. 2014).

B. Standard of Judicial Review

"Judicial review of Administration decisions under the Social Security Act is governed by 42 U.S.C. § 405(g). When, as here, an ALJ's decision constitutes the final action of the Social Security Administration, the district court examines the ALJ's decision to determine whether substantial evidence supports it and whether the ALJ applied the proper legal criteria." Allord v. Astrue, 631 F.3d 411, 415 (7th Cir. 2011) (citation omitted). Substantial evidence is "such relevant evidence as a reasonable mind might accept as adequate to support a conclusion." Moon v. Colvin, 763 F.3d 718, 721 (7th Cir. 2014). The district court must conduct a critical review of the evidence. Eichstadt v. Astrue, 534 F.3d 663, 665 (7th Cir. 2008).

This standard of review is deferential, but it does not require the district court to "scour the record for supportive evidence or [search] for reasons to uphold the ALJ's decision. Rather, the ALJ must identify the relevant evidence and build a logical bridge between that evidence and the ultimate determination." Moon, 763 F.3d at 721. If the ALJ's decision was not supported by substantial evidence, or misapplied the law, the district court can "affirm, reverse, or modify the [] decision, with or without remanding the case for further proceedings." Allord, 631 F.3d at 415 (citation omitted). Of these options, remand (to allow the ALJ to address the deficiencies in the original decision) is appropriate unless "all ...


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