Alice Gedatus v. Andrew Saul, 994 F.3d 893

Background:

Plaintiff Alice Gedatus (b. 1976) applied for SSDI alleging disability from May 11, 2010, based on lumbar degenerative disc disease (prior L5–S1 fusion), sciatica/back/leg/foot pain, knee and wrist issues, tremors, and residual effects of a 2010 subarachnoid hemorrhage.
Medical record shows multiple surgeries, repeated conservative treatments (injections, PT, braces), intermittent imaging with differing readings (notably a March 19, 2013 MRI with competing interpretations), and continuing complaints of limited sitting/standing tolerance and tremors; no treating physician submitted an RFC limiting sitting below the state-agency reviewers’ findings.
State-agency reviewers (Drs. Chan and Khorshidi) concluded she could perform light work, generally endorsing sit/stand tolerances of up to 6 of 8 hours and other moderate postural limits; no treating source opined greater restrictions.
ALJ found severe impairments: status-post lumbar fusion, right knee degenerative joint disease, and bilateral foot problems; treated the brain aneurysm and depression as non-severe and treated tremors as unsupported by objective evidence.
ALJ assessed an RFC for light work with added limits (e.g., no kneeling/crawling, only occasional balancing/stooping/climbing ramps/stairs, avoid unprotected heights, limited standing/walking to about 4 of 8 hours and—per hearing—sitting up to 6 of 8 hours), relied on a vocational expert who identified other available light, unskilled jobs, and denied benefits; district court and Appeals Council affirmed, and the Seventh Circuit likewise affirmed.

Issues:

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ improperly evaluated Gedatus’s subjective symptom testimony (boilerplate and selective summary)	ALJ used boilerplate language and selectively summarized evidence, mischaracterized imaging, and failed to apply the correct preponderance standard when discounting symptoms	ALJ provided non-boilerplate, case-specific reasons; reviewed medical record, activities, treatment, and state-agency opinions; substantial evidence supports credibility and RFC findings	Affirmed — ALJ gave specific, adequate reasons; substantial evidence supports the symptom evaluation
Whether ALJ violated SSR 96-8p by failing to explain sitting tolerance and by not assessing tremors’ functional effects	ALJ failed to include a narrative RFC discussion of sitting limits and did not assess tremors’ work impact per SSR 96-8p	Plaintiff offered no treating/consultative medical opinion imposing greater sitting limits or tremor-related functional restrictions; ALJ permissibly relied on state-agency RFCs and lack of objective support for tremors	Affirmed — no reversible error; ALJ permissibly concluded no additional RFC limits warranted and failure to supply a treating opinion was dispositive

Key Cases Cited:

Lopez v. Barnhart, 336 F.3d 535 (7th Cir. 2003) (review standard for ALJ decisions)
Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (definition of substantial evidence)
Biestek v. Berryhill, 139 S. Ct. 1148 (U.S. 2019) (substantial-evidence threshold is not high)
Rice v. Barnhart, 384 F.3d 363 (7th Cir. 2004) (absence of a treating/consulting opinion showing greater limitations supports ALJ reliance on state-agency opinions)
Steele v. Barnhart, 290 F.3d 936 (7th Cir. 2002) (ALJ must provide specific reasons when discounting subjective symptoms)
Jozefyk v. Berryhill, 923 F.3d 492 (7th Cir. 2019) (harmless-error principle when record lacks evidence specifying additional functional restrictions)
Schomas v. Colvin, 732 F.3d 702 (7th Cir. 2013) (summarizing extensive medical records is appropriate)
Terry v. Astrue, 580 F.3d 471 (7th Cir. 2009) (ALJ must build a logical bridge but need not discuss every piece of evidence)
Pepper v. Colvin, 712 F.3d 351 (7th Cir. 2013) (ALJ need not address every detail of daily activities when assessing RFC)
Castile v. Astrue, 617 F.3d 923 (7th Cir. 2010) (claimant bears burden to produce medical evidence establishing disability)