ALJ’s denial of disability benefits over potential side effects upheld

The 7^th Circuit Court of Appeals has affirmed an administrative law judge’s decision that a northern Indiana woman is not disabled, finding that any conclusions about her medication’s side effects would be pure speculation.

Meretha Arnold applied for Social Security disability benefits based on ailments related to her back, heart and joints, as well as chronic pain syndrome. After an initial denial of her claim, Arnold requested a hearing before an administrative law judge. In a written decision after the hearing, the ALJ concluded that Arnold was not disabled.

Although the ALJ found that Arnold had several severe impairments, the judge determined that she retained the ability, with certain movement restrictions, to perform her past relevant work as a daycare center director. Arnold appealed, claiming that the ALJ failed to analyze whether the side effects of her medications impacted her ability to work.

The U.S. District Court for the Northern District affirmed the ALJ’s decision and the 7^th Circuit Court of Appeals followed suit in a Thursday decision.

“Arnold claims that the ALJ improperly ignored other evidence of side effects in the record. For example, one of Arnold’s treating doctors told her not to work, drive, or operate heavy machinery while medicated. And her medical records indicate that a beta blocker medication made her tired and possibly fatigued; that Arnold thought one of her medications (Rhythmol) was causing her mouth sores, nightmares, and difficulty sleeping; and that Arnold occasionally became dizzy (though there was no express link between the dizziness and any medication),” Circuit Judge Amy St. Eve wrote for the 7^th Circuit.

“On this record, the ALJ was not required to make findings about Arnold’s side effects. Nothing in the record suggests that Arnold suffered side effects that actually impacted her ability to work. Arnold relies primarily on her doctor’s warning against working, driving, and operating heavy machinery while medicated. But this warning is not evidence that Arnold experienced these potential side effects,” the panel wrote. “At most, it is evidence that her medications could cause side effects — not that they did.”

Any conclusion about how Arnold’s side effects impacted her ability to work would be pure speculation, the 7^th Circuit concluded. Thus, it found that the ALJ did not have to make specific findings about side effects in the case of Meretha Arnold v. Andrew Saul, 20-2067.