Bradley Shideler v. Michael Astrue
688 F.3d 306
| 7th Cir. | 2012Background
- Shideler has osteogenesis imperfecta (brittle bone disease).
- He applied for Social Security Disability Insurance in 2006, with a disability onset date of June 30, 1995; insured date is March 31, 2000.
- An ALJ denied benefits; Appeals Council denied review; district court affirmed; Shideler appeals to Seventh Circuit.
- Hearing (2009) featured Shideler, his roommate, and a vocational expert; Shideler reported severe pain and mobility limitations.
- Record showed few medical records before 2000, a 1999 knee surgery with recovery and no restrictions thereafter, and no fracture events documented between 2000 and 2006.
- The ALJ found Shideler not disabled before March 31, 2000, despite restricting him to a sedentary range and considering (a) limited fingering, (b) no overhead reaching, (c) avoidance of extreme temperatures, and (d) simple routine tasks.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ properly evaluated credibility | Shideler argues credibility was not adequately supported | ALJ considered medical history, testimony, and consistency with records | Credibility supported; not patently wrong |
| Whether substantial evidence supports disability decision for 1995–2000 | Shideler contends there were fewer or no jobs suitable given limitations | Vocational expert identified several sedentary, available jobs in the region | Yes; substantial evidence supports non-disability prior to insured date |
Key Cases Cited
- Skarbek v. Barnhart, 390 F.3d 500 (7th Cir. 2004) (patent credibility determination review deference)
- Simila v. Astrue, 573 F.3d 503 (7th Cir. 2009) (requirement to consider all evidence and articulate analysis)
- Johnson v. Barnhart, 449 F.3d 804 (7th Cir. 2006) (need for a logical bridge from evidence to conclusion)
- Schmidt v. Barnhart, 395 F.3d 737 (7th Cir. 2005) (build a logical bridge; not required to discuss every strand of evidence)
- Scheck v. Barnhart, 357 F.3d 697 (7th Cir. 2004) (credibility findings entitled to deference if supported by record)
- Martinez v. Astrue, 630 F.3d 693 (7th Cir. 2011) (disabled status tied to insured period; later disability cannot retroactively apply)
- Jens v. Barnhart, 347 F.3d 209 (7th Cir. 2003) (administrative decisions need not mention every piece of evidence)
- Elder v. Astrue, 529 F.3d 408 (7th Cir. 2008) (substantial evidence standard and deference to ALJ)