Ashley Gerstner v. Nancy A. Berryhill, 879 F.3d 257

Ashley Gerstner applied for disability insurance benefits and SSI alleging onset May 2011; claimed severe mental impairments (anxiety, bipolar disorder, panic disorder, depression) and fibromyalgia preventing work.
Longstanding psychiatric treatment: Dr. Stephen Callaghan (psychiatrist) treated her since 2006 and completed a mid‑2012 assessment finding extreme limitations (e.g., 2–3 hours workable per day, likely to miss 7 days/month); subsequent treatment notes repeatedly diagnosed depression/dysthymia and adjusted medications.
Supporting treating/therapy evidence: psychologist Dr. David Nichols (GAF scores 40–55) and nurse practitioner Nancy Maczka offered similar limiting opinions.
Medical workup for pain: neurologist and rheumatologist evaluated her; trigger‑point testing and 14/18 tender points supported fibromyalgia; treated by primary care with Lyrica and later methadone.
State reviewing consultant (June 2012) concluded only moderate limitations; ALJ gave that opinion great weight and gave Dr. Callaghan’s mid‑2012 opinion little weight, discounting Gerstner’s symptom testimony and concluding she retained capacity for light, unskilled work with limits (no public contact, occasional co‑worker interaction).
The district court (magistrate judge) affirmed; the Seventh Circuit vacated and remanded, finding the ALJ erred in assessing the treating psychiatrist’s opinion and in the credibility finding regarding fibromyalgia pain.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Weight given to treating psychiatrist Dr. Callaghan's mid‑2012 opinion	ALJ improperly gave it little weight; he cherry‑picked benign mood/affect notes, ignored consistent diagnoses/treatment history and supporting opinions, and failed to apply 20 C.F.R. § 404.1527(c) factors	ALJ relied on ostensibly ‘‘normal’’ mental status findings and state‑agency reviewer (Dr. Childs) to justify discounting extreme limitations	Reversed: ALJ erred by selectively relying on parts of the record, failing to consider supporting evidence and §404.1527(c) factors; remand required for reassessment
Credibility of fibromyalgia pain complaints	ALJ improperly discounted her pain testimony by overstating exam findings, misreading recommendations to increase activity, inferring falsity from a 6‑month medication gap without considering loss of insurance, and relying on job‑search notes	ALJ argued objective exam findings and treatment gaps undermined claimant's symptom allegations	Reversed: credibility finding was patently wrong—ALJ misstated/misunderstood evidence and drew unjustified inferences; remand for proper evaluation

Brown v. Colvin, 845 F.3d 247 (7th Cir.) (treating physician rule and weight of treating opinions)
Campbell v. Astrue, 627 F.3d 299 (7th Cir.) (ALJ may not selectively discuss favorable portions of a physician's report)
Meuser v. Colvin, 838 F.3d 905 (7th Cir.) (remand required when ALJ inadequately weighs treating source opinion)
Price v. Colvin, 794 F.3d 836 (7th Cir.) (importance of considering all psychiatric treatment notes, even patient‑reported symptoms)
Larson v. Astrue, 615 F.3d 744 (7th Cir.) (standard for overturning patently wrong credibility findings)
Vanprooyen v. Astrue, 864 F.3d 567 (7th Cir.) (limitations of objective testing for fibromyalgia; trigger‑point testing relevant)