Ali v. Bisignano
1:22-cv-06409
N.D. Ill.Jun 27, 2025Background
- Plaintiff Komawi A. applied for disability benefits, alleging disability from December 2012 based on mental and physical impairments.
- His initial application was denied by an ALJ in 2015; the denial was upheld by the Appeals Council.
- A second application was filed in 2016 while the first denial was appealed; the district court remanded the decision for further evaluation of medical opinion evidence, especially that of plaintiff's treating physicians.
- Following remand, ALJ Sayon held a new hearing and again found plaintiff not disabled, relying on state agency medical opinions over treating sources.
- The case returned to the district court, where plaintiff challenged the ALJ's reliance on non-examining state physician opinions and the handling of treating physician evidence regarding his functional capacity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly weighted medical opinions in determining RFC | ALJ improperly discounted treating doctors, relied on non-examiner | ALJ properly weighed evidence, explained decision | ALJ erred by over-relying on non-examining doctor |
| Whether ALJ could discount severity based on failure to adhere to treatment | ALJ did not inquire into reasons for non-compliance | ALJ properly relied on failure to follow recommendations | ALJ failed to properly investigate non-compliance |
| Whether substantial evidence supported physical RFC determination | State doctor’s opinion outdated, did not include later imaging | Later imaging consistent with RFC, ALJ’s medical review | ALJ erred interpreting post-dated medical evidence |
| Whether ALJ built a logical bridge between evidence and conclusion | ALJ did not explain how newer evidence fit prior medical opinion | Sufficient reasoning provided | No logical bridge; remand required |
Key Cases Cited
- Young v. Sec'y of Health & Human Servs., 957 F.2d 386 (7th Cir. 1992) (describes disability evaluation process and burden shifting at steps)
- Biestek v. Berryhill, 587 U.S. 97 (2019) (clarifies "substantial evidence" standard in Social Security appeals)
- Ray v. Berryhill, 915 F.3d 486 (7th Cir. 2019) (ALJ must inquire into reasons for treatment non-compliance before discounting claims)
- McHenry v. Berryhill, 911 F.3d 866 (7th Cir. 2018) (ALJs cannot interpret complex medical tests without expert input)