Arnett v. Astrue
676 F.3d 586
| 7th Cir. | 2012Background
- Arnett applied for Disability Insurance Benefits alleging onset June 14, 2002, due to multiple medical conditions.
- ALJ denied benefits; Appeals Council denied review; district court denied review; this court reviews for substantial evidence with the ALJ’s rationale.
- ALJ found two conditions severe (PVD and COPD) and declined to treat mental impairments as severe; RFC limited to sedentary work with sit/floor bounds and sit-stand alternation.
- Evidence included extensive vascular, pulmonary, and musculoskeletal diagnoses; multiple treating and consulting physicians offered varied RFC assessments; dementia and obesity were among contested impairments not clearly integrated into RFC.
- ALJ’s RFC did not adequately account for mental impairments (depressive, anxiety, panic) or several physical impairments (obesity, lumbosacral neuritis, osteoarthritis, degenerative disc disease, sacroiliac changes); court remands for further proceedings.
- Court reverses and remands to SSA for proper RFC assessment accounting for all impairments and obesity under SSR 96-9p and relevant case law.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the RFC properly includes mental impairments | Arnett's dementia and anxiety disorders must constrain RFC | ALJ properly considered evidence, treating mental impairments as non-severe | Remand required for proper mental RFC integration. |
| Whether obesity and other physical impairments were considered in aggregate | ALJ failed to consider obesity and other impairments cumulatively | Obesity considered indirectly through physician limitations | Remand due to inadequate consideration of obesity and related impairments. |
| Whether the ALJ erred by not detailing how impairments affect RFC | RFC lack of specificity about sit/stand frequency | RFC sufficiently defined | Remand to specify sit/stand frequencies and ensure traceability to evidence. |
| Whether the RFC should reflect lumbosacral neuritis, degenerative disc disease, and related conditions | ALJ ignored lines of evidence on spine and joints | Some diagnoses were non-severe or uncertain | Remand to evaluate these impairments and their impact on work capacity. |
Key Cases Cited
- Castile v. Astrue, 617 F.3d 923 (7th Cir.2010) (severity at Step 2 is threshold; reversal not required for harmless error)
- Eichstadt v. Astrue, 534 F.3d 663 (7th Cir.2008) (ALJ must connect evidence to conclusion for meaningful review)
- Parker v. Astrue, 597 F.3d 920 (7th Cir.2010) (credibility findings; not entirely credible standard)
- Spiva v. Astrue, 628 F.3d 346 (7th Cir.2010) (consideration of all evidence; not harmless error when evidence neglected)
- Ketelboeter v. Astrue, 550 F.3d 620 (7th Cir.2008) (RFC must specify sit/stand frequency)
- Schmidt v. Astrue, 496 F.3d 833 (7th Cir.2007) (RFC specificity for sitting/standing)
- Shramek v. Apfel, 226 F.3d 809 (7th Cir.2000) (appeals review of district court decisions; waiver context)
- Zurawski v. Halter, 245 F.3d 881 (7th Cir.2001) (ALJ may not ignore lines of evidence; combination of impairments)
- Martinez v. Astrue, 630 F.3d 693 (7th Cir.2011) (obesity must be considered in aggregate impairments)