72 F.4th 810
7th Cir.2023Background
- Angela Crowell applied for Supplemental Security Income alleging disability with an amended onset date of January 1, 2012; the SSA denied benefits and the case underwent multiple remands and appeals, with the relevant ALJ decision issued June 12, 2018 and the district court denying relief on October 25, 2022.
- ALJ found severe impairments: fibromyalgia, depressive disorder, anxiety disorder, and residual left-shoulder impairment; other conditions (asthma, back issues, substance use, “absence” spells) were not found severe.
- The ALJ reviewed about 17 medical providers and 184 exhibits, and credited state agency psychologists’ opinions (Drs. Rattan and Fiore) over treating physician Dr. Gary Steele.
- ALJ assessed an RFC for light work limited to simple, routine, repetitive tasks; simple work-related decisions; occasional workplace changes; occasional interaction with others and public; no fast-paced work; avoid heights/hazards/dangerous machinery; limited upper-extremity demands.
- Crowell challenged the sufficiency of the evidence supporting the ALJ’s RFC, the discounting of Dr. Steele’s opinions, reliance on her babysitting and Facebook activity, and alleged failure to properly consider bipolar disorder; the Seventh Circuit affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ's RFC is supported by substantial evidence | Crowell: RFC ignores evidence of disabling limitations and misweighs records | SSA: ALJ reasonably weighed the record and built a logical bridge to RFC | Court: RFC supported by substantial evidence; deferential review applies |
| Weight accorded to treating physician Dr. Steele | Crowell: ALJ should have given controlling weight to Steele’s opinions | SSA: ALJ permissibly discounted Steele for lack of specialization, vagueness, timing, and inconsistency | Court: ALJ reasonably explained reasons for giving little weight to Steele |
| Use of daily activities (babysitting, Facebook) as evidence of functioning | Crowell: ALJ overstated significance—daily activities differ from full-time work | SSA: ALJ may consider daily activities as part of the overall record | Court: ALJ permissibly considered activities among other evidence; not reversible error |
| Failure to list bipolar disorder at Step Two | Crowell: ALJ erred by omitting bipolar disorder as a severe impairment | SSA: ALJ considered bipolar symptoms in the mental-health analysis | Court: Any omission was harmless—bipolar disorder was considered in the analysis and did not change outcome |
Key Cases Cited
- Biestek v. Berryhill, 139 S. Ct. 1148 (the substantial-evidence threshold in Social Security cases is low)
- Simila v. Astrue, 573 F.3d 503 (explaining substantial-evidence standard in Seventh Circuit)
- Butler v. Kijakazi, 4 F.4th 498 (ALJ must provide a logical bridge between evidence and conclusions)
- Elder v. Astrue, 529 F.3d 408 (court will not reweigh evidence or substitute its judgment for ALJ if supported by substantial evidence)
- Gedatus v. Saul, 994 F.3d 893 (ALJ not required to list every document considered; must weigh relevant evidence)
- Grotts v. Kijakazi, 27 F.4th 1273 (permissible to credit state-agency experts over treating physician when reasons articulated)
- Prill v. Kijakazi, 23 F.4th 738 (treating-source weight not automatic; ALJ must consider regulatory factors)
- Berger v. Astrue, 516 F.3d 539 (daily activities can be considered in evaluating claimant’s statements)
- Jeske v. Saul, 955 F.3d 583 (administrative regulations allow consideration of daily-living activities in symptom evaluation)
- Hofslien v. Barnhart, 439 F.3d 375 (ALJ may discount treating physician if opinion appears tailored to help claimant obtain benefits)