Chad Ray v. Andrew Saul, 20-2802

Chad Ray, long-time welder/millwright, suffered chronic back pain after a 2012 back surgery and stopped working thereafter.
Ray had a second surgery in January 2016 (hardware removal) with some temporary improvement; he used a cane and later a wheelchair.
He applied for Social Security disability for the period January 23, 2015–December 31, 2017 (date last insured).
Treating physician Dr. Diane Zaragoza repeatedly reported Ray disabled (including a May 2015 letter and an April 2018 questionnaire); agency consultants and an impartial medical expert concluded Ray could perform some sedentary work.
At the ALJ hearing Ray testified about severe pain; the ALJ gave little weight to Dr. Zaragoza, credited the agency consultants and the impartial expert, found an RFC for sedentary work, and denied benefits; the district court affirmed.
The Seventh Circuit affirmed, holding the ALJ’s decision supported by substantial evidence and any failure to expressly address every treating‑physician factor was harmless.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Weight given to treating physician's opinion	ALJ improperly discounted Dr. Zaragoza and should have given controlling weight	Treating opinion was inconsistent, sometimes conclusory (ultimate disability), and post‑dated the last insured date	ALJ reasonably discounted Zaragoza; substantial evidence supports that decision
Failure to expressly apply 20 C.F.R. § 404.1527(c) factors	ALJ did not explicitly analyze every required checklist factor for a treating source	Any omission is harmless because the ALJ’s reasoning implicitly addressed the factors and record undermines Zaragoza’s opinion	Error in not listing every factor was harmless; no remand required
Credibility of Ray’s subjective pain testimony	Ray’s testimony and daily‑living evidence show disabling limitations	Medical records, consultants, and impartial expert contradict the severity claimed	ALJ gave a reasoned credibility determination supported by substantial evidence; not patently wrong
Effect of worsening condition after last insured date (2018 evidence)	Post‑period deterioration shows disability and should weigh in claimant’s favor	2018 worsening post‑dates last insured and lacks evidence tying it back into the insured period	Court held 2018 decline does not establish disability during the 2015–2017 period; ALJ did not err reversibly

Biestek v. Berryhill, 139 S. Ct. 1148 (Sup. Ct. 2019) (describing the "substantial evidence" threshold as not high)
Karr v. Saul, 989 F.3d 508 (7th Cir. 2021) (ALJ must analyze treating‑source opinion within the regulatory multifactor framework)
Bates v. Colvin, 736 F.3d 1093 (7th Cir. 2013) (treating physician opinion loses controlling weight when record contains contrary evidence)
Clifford v. Apfel, 227 F.3d 863 (7th Cir. 2000) (physician’s statement that claimant is "disabled" is an administrative conclusion reserved to the Commissioner)
Campbell v. Astrue, 627 F.3d 299 (7th Cir. 2010) (mere acknowledgement of factors is insufficient; analysis must reflect the factors’ substance)
Gerstner v. Berryhill, 879 F.3d 257 (7th Cir. 2018) (ALJ should evaluate treating‑source opinion within the regulation’s multifactor framework)
McKinzey v. Astrue, 641 F.3d 884 (7th Cir. 2011) (ALJ must provide sufficient explanation for symptom‑severity findings)
Elder v. Astrue, 529 F.3d 408 (7th Cir. 2008) (credibility findings will not be overturned unless "patently wrong")
Summers v. Berryhill, 864 F.3d 523 (7th Cir. 2017) (claimant bears the burden of proving disability)
Gedatus v. Saul, 994 F.3d 893 (7th Cir. 2021) (outlining factors for evaluating a claimant’s statements about pain)