United States District Court, E.D. Kentucky
CENTRAL DIVISION AT LEXINGTON PLAINTIFF MEMORANDUM OPINION AND ORDER
DAVID L. BUNNING, District Judge.
This matter is before the Court on Plaintiff's and Defendant's cross motions for summary judgment. Because the Commissioner's decision is supported by substantial evidence and was made according to proper legal standards, Plaintiff's motion (Doc. #9) shall be denied, and Defendant's motion (Doc. #10), shall be granted.
II. FACTUAL AND PROCEDURAL BACKGROUND
Plaintiff Tiffany Warford is a Kentucky resident who has allegedly suffered from disabling psychological problems since November 1999. (Doc. #7-1 at 16). Her initial application for supplemental security income was denied on November 10, 2010, and her later request for reconsideration was denied on February 22, 2011. ( Id. ) Plaintiff then requested a hearing, which was held on January 19, 2012, before Administrative Law Judge (ALJ) Brian LeCours. ( Id. ) ALJ LeCours held a further hearing via teleconference on March 14, 2012, to consider new evidence. ( Id. )
In his written opinion, ALJ LeCours weighed the importance of various pieces of evidence, including Plaintiff's testimony and the medical evaluations of multiple doctors. The ALJ found that Plaintiff's claims regarding the severity of her symptoms were suspect because of Plaintiff's treatment and work histories. (Doc. #7-1 at 23). ALJ Lecours also considered the medical opinions of Drs. Genthner and Ford, neither of whom had established a treatment relationship with the Plaintiff. Because each doctor's conclusions conflicted with Plaintiff's work history, the ALJ afforded little weight to their opinions regarding Plaintiff's work limitations. ( Id. at 25). On the basis of this evidence and the testimony of two vocational experts, the ALJ concluded that although Plaintiff did have some work limitations, Plaintiff could perform enough jobs in the national economy to preclude an award of disability under the Social Security Act. ( Id. at 26-27).
Plaintiff then brought an appeal under Section 205 of the Social Security Act. (Doc. #1). That appeal culminated in cross-motions for summary judgment, (Docs. #9, 10), which are now ripe for review.
III. STANDARD OF REVIEW
The Court's review is limited to determining whether the Commissioner's decision followed proper legal standards and whether the Commissioner's findings are supported by substantial evidence. Rogers v. Comm'r of Soc. Sec., 486 F.3d 234, 241 (6th Cir. 2007). Under this deferential standard, courts will not substitute their judgment for that of the ALJ. Id. The Court does not resolve evidentiary conflicts or decide questions of credibility. Cutlip v. Sec'y of Health & Human Servs., 25 F.3d 284, 286 (6th Cir. 1994). Interpretations of statutes and agency regulations are questions of law, which the Court will review de novo. Smith v. Comm'r of Soc. Sec., 482 F.3d 873, 876 (6th Cir. 2007).
A. The five-step process and the residual functional capacity
In deciding whether to award disability benefits, the ALJ must proceed through a five-step analysis. Heston v. Comm'r of Soc. Sec., 245 F.3d 528, 534 (6th Cir. 2001). At step one, the ALJ determines whether the applicant is gainfully employed. 20 C.F.R. § 404.1520(b). At step two, the issue is whether the applicant suffers from any serious physical or mental impairments. Id. at § 1520©. Assuming the answer is yes, the ALJ then considers whether the applicant's impairments are among those listed in Social Security regulations, such that the applicant is presumed disabled. Id. at § 1520(d).
Neither party disputes the ALJ's fact finding with regards to the first three steps: Plaintiff is not currently employed and does suffer from some significant impairments, but none of these impairments are among those listed in agency regulations. The ALJ found as much in his written opinion. (Doc. #7-1 at 21).
If a claimant's impairments fail to qualify as a listed impairment under agency regulations, the ALJ must then prepare a residual functional capacity (RFC). 20 C.F.R. § 404.1520(e). This RFC is used at both steps four and five of the decision making process. Id. at § 1520(a)(4). At step four, the ALJ decides, in light of the RFC, whether the claimant can perform any past relevant work. Id. at § 1520(a)(4)(iv). If so, then the claimant is not eligible for benefits. Id. If not, the ALJ then considers alternative work the claimant could do, and evaluates whether enough of that work exists in the national economy to preclude an award of disability ...