United States District Court, E.D. Kentucky, Northern Division, Ashland
JOSEPH M. HOOD, Senior District Judge.
This matter is before the Court upon cross-motions for summary judgment on Plaintiff's appeal of the Commissioner's denial of her application for supplemental security income (SSI). The Court, having reviewed the record and considered the parties' arguments, finds that the decision of the Administrative Law Judge is supported by substantial evidence and, thus, the Court will grant Defendant's motion and deny Plaintiff's motion.
I. Overview of the Process and the Instant Matter
The Administrative Law Judge (ALJ), in determining disability, must conduct a five-step analysis:
1. An individual who is working and engaging in substantial gainful activity is not disabled, regardless of the claimant's medical condition.
2. An individual who is not working but does not have a "severe" impairment which significantly limits his physical or mental ability to do basic work activities is not disabled.
3. If an individual is not working and has a severe impairment which "meets the duration requirement and is listed in appendix 1 or is equal to a listed impairment(s)", then he is disabled regardless of other factors.
4. If a decision cannot be reached based on current work activity and medical facts alone, and the claimant has a severe impairment, then the Secretary reviews the claimant's residual functional capacity and the physical and mental demands of the claimant's previous work. If the claimant is able to continue to do this previous work, then he is not disabled.
5. If the claimant cannot do any work he did in the past because of a severe impairment, then the Secretary considers his residual functional capacity, age, education, and past work experience to see if he can do other work. If he cannot, the claimant is disabled.
Preslar v. Sec'y of Health & Human Servs., 14 F.3d 1107, 1110 (6th Cir. 1994) (citing 20 C.F.R. § 404.1520 (1982)). "The burden of proof is on the claimant throughout the first four steps of this process to prove that he is disabled." Id. "If the analysis reaches the fifth step without a finding that the claimant is not disabled, the burden transfers to the Secretary." Id.
The Plaintiff has not worked since 2012. The ALJ determined that she had severe impairments including: mood disorder; substance abuse in reported remission; and major joint dysfunction. The ALJ determined, however, that none of the impairments met or medically equaled the severity of an impairment listed in Appendix 1. After considering the medical evidence, the ALJ found that Plaintiff has the residual functional capacity (RFC) to perform less than a full range of light work as defined in 20 C.F.R. § 416.967(b). The ALJ found that Plaintiff can frequently climb ramps or stairs and that she can occasionally climb ladders, ropes, or scaffolds. The ALJ determined that Plaintiff can frequently stoop, kneel, and crouch, and that she can occasionally crawl. Plaintiff is limited to frequent handling. The ALJ determined that Plaintiff should avoid concentrated exposure to pulmonary irritants. Further, she is limited to simple tasks with no interaction with the general public. The ALJ found that Plaintiff can have occasional interaction with co-workers and supervisors and is limited to low stress work, defined as no fast-paced production.
The ALJ determined that, although Plaintiff was not able to perform any past relevant work, there are jobs that exist in significant numbers in the national economy that Plaintiff can perform and, therefore, Plaintiff is not disabled.
II. Standard of Review
In reviewing the ALJ's decision to deny disability benefits, the Court may "not try the case de novo, nor resolve conflicts in the evidence, nor decide questions of credibility." Cutlip v. Sec'y of Health & Human Servs., 25 F.3d 284, 286 (6th Cir. 1994) (citations omitted). Instead, judicial review of the ALJ's decision is limited to an inquiry into whether the ALJ's findings were supported by substantial evidence, 42 U.S.C. § 405(g); Foster v. Halter, 279 F.3d 348, 353 (6th Cir. 2001) (citations omitted), and whether the ALJ employed the proper legal standards in reaching her conclusion. See Landsaw v. Sec'y of Health & Human Servs., 803 F.2d 211, 213 (6th Cir. 1986). "Substantial evidence is more than a scintilla of ...