Bates v. Colvin
2013 U.S. App. LEXIS 23999
| 7th Cir. | 2013Background
- Bates sought SSI after neck pain and later mental health impairments following a 2004 car accident.
- Medical records span 2004–2009, showing cervical radiculopathy, pain management, and intermittent treatment.
- Bates’s treating psychiatrist diagnosed Bipolar Type 2 in 2009; therapist documented mood and functional impairments.
- An ALJ denied SSI; district court affirmed, and Bates appealed for remand based on treating-opinion and credibility errors.
- The court remanded, finding error in the ALJ’s handling of treating-physician opinions and mental-health credibility.
- Foundational issues include evaluation of pain testimony, credibility of mental-health claims, and RFC determination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ properly evaluate Bates’s pain testimony? | Bates's pain testimony was credible and supported by records. | ALJ properly discounted pain based on inconsistencies and limited objective findings. | Remand for reevaluation of pain credibility and related RFC effects. |
| Did the ALJ properly credit Bates’s treating-physician opinions? | Cordero and Shahzaad opinions should receive controlling weight. | ALJ properly discounted treating opinions in light of credibility findings and record. | Remand to reconsider treating-physician opinions under proper standards. |
| Did the ALJ properly assess Bates’s mental health and concentration, persistence, and pace? | ALJ disregarded significant psychiatric evidence and mischaracterized records. | ALJ’s mental-health assessment relied on substantial evidence and context. | Remand for proper consideration of mental-health limitations and GAF/contextual evidence. |
Key Cases Cited
- Castile v. Astrue, 617 F.3d 923 (7th Cir. 2010) (de novo review of district court in disability appeals)
- Jelinek v. Astrue, 662 F.3d 805 (7th Cir. 2011) (standard for substantial evidence review and credibility)
- Pepper v. Colvin, 712 F.3d 351 (7th Cir. 2013) (creditability determinations given deference unless patently wrong)
- Herron v. Shalala, 19 F.3d 329 (7th Cir. 1994) (cannot rely only on evidence that supports your opinion)
- Roddy v. Astrue, 705 F.3d 631 (7th Cir. 2013) (treating-physician opinions and RFC relationship)