Campbell v. Astrue
627 F.3d 299
| 7th Cir. | 2010Background
- Campbell applied for disability benefits and SSI on January 13, 2004, focusing on mental impairments.
- Treating psychiatrist Dr. Powell diagnosed Major Depressive Disorder with psychotic features and Bipolar Disorder with psychotic features; GAF ratings commonly 45-50.
- ALJ denied benefits on August 24, 2006, discounting Dr. Powell's mental-health assessment and favoring non-treating opinions (Dr. Marquis and state-agency consultants).
- Appellate court in district court upheld the denial; Campbell challenged ALJ's weighting of Dr. Powell's testimony and consideration of alcohol use.
- Seventh Circuit held the ALJ's treatment of Dr. Powell's opinion and consideration of alcohol use inadequate under governing regulations and case law.
- Case remanded for further proceedings consistent with the opinion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ err by discounting Dr. Powell's opinion? | Powell's opinion should be given controlling weight as treating psychiatrist. | ALJ properly weighed evidence and considered consistency with the record. | Yes; discounting Powell was not supported by substantial evidence. |
| Did the ALJ adequately apply the treating-physician weight factors? | ALJ failed to use the required factors (length, nature, frequency, specialty, tests, consistency). | ALJ considered opinion evidence under applicable regulations. | No; factors were not explicitly applied. |
| Did the ALJ improperly rely on partial readings of Powell's December 22, 2005 assessment (Cheney issue)? | ALJ cherry-picked sections and ignored the six-page report as a whole. | ALJ's reliance on the cited portions was permissible under the record. | No; improper selective discussion violated Myles/Cheney concerns. |
| Did the ALJ fail to evaluate the impact of alcohol use on Campbell's functioning? | Alcohol use was a significant factor; Powell noted abstinence but its effect remained relevant. | Alcohol use declined and was not a factor by late 2005. | Yes; failure to adequately assess alcohol's role tainted the decision. |
Key Cases Cited
- Larson v. Astrue, 615 F.3d 744 (7th Cir. 2010) (treating-physician weight factors must be explicitly considered)
- Myles v. Astrue, 582 F.3d 672 (7th Cir. 2009) (do not selectively discuss portions of a medical report)
- Cheney Corp. v. SEC, 318 U.S. 80 (S. Ct. 1943) (Chenery doctrine; cannot rely on post hoc rationalizations)
- Bauer v. Astrue, 532 F.3d 606 (7th Cir. 2008) (apply checklist factors when not granting controlling weight)
- Castile v. Astrue, 617 F.3d 923 (7th Cir. 2010) (substantial evidence review; proper articulation of reasoning)
- Skinner v. Astrue, 478 F.3d 836 (7th Cir. 2007) (standard of review for SSA determinations)