LOUISE W. FLANAGAN, District Judge.
This matter is before the court on the parties' cross-motions for judgment on the pleadings. (DE 20, 22). Pursuant to 28 U.S.C. § 636(b)(1) and Federal Rule of Civil Procedure 72(b), United States Magistrate Judge Robert T. Numbers, II, entered memorandum and recommendation ("M&R"), wherein it is recommended that the court deny plaintiff's motion, grant defendant's motion, and affirm defendant's decision. Plaintiff timely filed objections to the M&R, and the issues raised are ripe for ruling. For the reasons that follow, the court adopts the M&R as its own, grants defendant's motion, denies plaintiff's motion, and affirms defendant's final decision.
On November 17, 2014, plaintiff protectively filed a Title II application for disability benefits, and on November 24, 2014, plaintiff filed a Title XVI application for supplemental security income. In both applications, plaintiff alleged disability beginning May 8, 2014. The claim was denied initially and upon reconsideration. Plaintiff requested hearing before an administrative law judge ("ALJ"), who, after a June 20, 2017, video hearing, denied plaintiff's claim by decision entered July 21, 2017. Following the ALJ's denial of the claim, plaintiff timely requested review, and the Appeals Council denied plaintiff's request for review, leaving the ALJ's decision as defendant's final decision. Plaintiff then filed a complaint in this court on June 22, 2018, seeking review of defendant's decision.
The court has jurisdiction under 42 U.S.C. § 405(g) to review defendant's final decision denying benefits. The court must uphold the factual findings of the ALJ "if they are supported by substantial evidence and were reached through application of the correct legal standard."
"A necessary predicate to engaging in substantial evidence review is a record of the basis for the ALJ's ruling," including "a discussion of which evidence the ALJ found credible and why, and specific application of the pertinent legal requirements to the record evidence."
To assist it in its review of defendant's denial of benefits, the court may "designate a magistrate judge to conduct hearings . . . and to submit . . . proposed findings of fact and recommendations for the disposition [of the motions for judgment on the pleadings]."
The ALJ's determination of eligibility for Social Security benefits involves a five-step sequential evaluation process, which asks whether:
In the instant matter, the ALJ performed the sequential evaluation. At step one, the ALJ found that plaintiff had not engaged in substantial gainful activity since May 8, 2014, the alleged onset date. (Transcript of the Record ("Tr.") 18). At step two, the ALJ found plaintiff had the following severe impairments: "degenerative joint disease, knees; migraine headaches; history of stroke; and pseudobulbar symptoms." (Tr. 18). The ALJ also found non-severe impairments: "depression, obesity, and substance addiction." (Tr. 18). At step three, the ALJ determined that these impairments were not severe enough, either individually or in combination, to meet or medically equal one of the listings in the regulations. (Tr. 20).
Before proceeding to step four, the ALJ determined that during the relevant time period plaintiff had the residual functional capacity ("RFC") to perform medium work with the following limitations:
(Tr. 24). At step four, the ALJ concluded plaintiff is unable to perform any past relevant work. (Tr. 35). At step five, the ALJ determined that there are jobs that exist in significant numbers in the national economy that plaintiff can perform. (Tr. 36). Thus, the ALJ concluded that plaintiff was not disabled under the terms of the Social Security Act. (Tr. 37).
Plaintiff argues in her objections that the ALJ erred in 1) failing to sufficiently address plaintiff's migraines in formulating her RFC, and 2) failing to sufficiently address plaintiff's pseudobulbar affect. The magistrate judge cogently addressed both arguments. (
"[A] proper RFC analysis has three components: (1) evidence, (2) logical explanation, and (3) conclusion."
Plaintiff argues that the ALJ failed to adequately account for her migraines. A review of the ALJ's decision shows otherwise. The ALJ extensively recounts plaintiff's treatment history. (
Finally, the ALJ determined that, based on treatment notes, plaintiff's application materials, and her testimony, that she engaged in various household chores and other activities of daily living. (Tr. 30, 71-75, 105, 114, 252, 261). Contrary to plaintiff's assertion, the ALJ's analysis acknowledges that plaintiff "helps in housework," accounting for the fact that she did not always engage in her activities of daily living alone. (Tr. 30). Taking all these factors into consideration, the ALJ adequately explained his reasoning for assigning limitations as a result of plaintiff's migraines, based on substantial evidence that plaintiff's migraines are under control. (
Plaintiff also argues that the ALJ failed to adequately account for her pseudobulbar affect, which results in uncontrollable laughing or crying at inappropriate times. (
Moreover, the ALJ indicated that, on virtually every visit to the doctor, plaintiff was alert, cooperative, had a normal mood and affect, and had a normal attention and concentration span. (
Based on the foregoing, upon careful review of the M&R and the record, the court ADOPTS the M&R as its own. Plaintiff's motion for judgment on the pleadings (DE 20) is DENIED, and defendant's motion for judgment on the pleadings (DE 22) is GRANTED. The clerk of court is DIRECTED to close this case.
SO ORDERED.