7th Circuit upholds denial of disability benefits despite ‘several medical problems’

An administrative law judge did not err in finding that a woman was not entitled to disability benefits despite having “several medical problems,” the 7^th Circuit Court of Appeals held Wednesday.

The plaintiff-appellant, identified only as “Deborah M.” in the 7th Circuit’s opinion, filed for disability benefits in 2016, alleging heart and back problems, arthritis, neuropathy and carpal tunnel syndrome. But based on “a mountain of evidence,” the ALJ determined Deborah could perform “light work,” noting her medical problems were not “of such frequency, duration, or intensity as to prevent her from” performing light work. Thus, the Social Security Administration denied Deborah’s application for benefits.

Deborah appealed the ALJ’s decision to the U.S. District Court for the Southern District of Indiana, seeking a remand based on reversible error. The district court, however, affirmed the ALJ, and the 7^th Circuit affirmed the district court on Wednesday.

Writing for a unanimous appellate panel, 7th Circuit Judge Michael Kanne first noted that while an ALJ doesn’t have to address every piece of evidence, the judge also can’t “ignore a line of evidence supporting a finding of disability.” Here, Kanne wrote, the ALJ engaged in a “more than adequate” discussion of the evidence.

Deborah had alleged the ALJ erred by omitting a specific discussion of her back pain, but the 7^th Circuit disagreed, pointing to Jones v. Astrue, 623 F.3d 1155 (7^th Cir. 2010).

“The omitted evidence that Plaintiff highlights, like the omitted evidence in Jones, did not reveal any substantially different information about her back problems than did the evidence that the ALJ addressed,” Kanne wrote. “As a result, it was not improper for the ALJ to omit a specific discussion of it.”

Deborah also argued the ALJ improperly “played doctor” and erred by finding her daily activities contradicted the alleged intensity of her symptoms. The 7th Circuit disagreed with those arguments as well.

“Here, the ALJ mentioned that Plaintiff lacked ‘nerve root impingement’ in her spine and that she did not receive surgery or other treatments for her spinal issues,” Kanne wrote. “In mentioning this lack of impingement and treatment, the ALJ was not playing doctor. Rather, she was just considering Plaintiff’s condition and treatment … and providing additional facts in support of her credibility analysis.”

Further, the ALJ did not violate Social Security Rule 16-3p by failing to ask about Deborah’s failure to seek treatment, because the rule only requires an ALJ to “consider possible reasons for a failure to seek treatment.” The judge did that here, noting in her ruling that Deborah “reported that she was doing well.”

As to the ALJ’s findings of contradictions between Deborah’s daily activities and the intensity of her symptoms, the panel pointed to one sentence in the judge’s decision: “While [daily] activities are not being compared to actual work situations, I do not consider evidence regarding the claimant’s daily activities as sufficient to establish that she is unable to function at the level I have assessed.”

“In other words,” Kanne wrote, “the ALJ correctly looked at Plaintiff’s daily activities to see if they corroborated her pain claims, and she found that they did not. She did not equate Plaintiff’s activities to full-time work.”

Finally, the panel noted that “two doctors who determined that she had ‘severe’ carpal tunnel syndrome nonetheless found that she did not have manipulative limitations.” Thus, the ALJ did not err in finding that the record did not show “the claimant is disabled or even has limitations greater than those determined in this decision.”

The case is Deborah M. v. Andrew M. Saul, 20-2570.