Charles Kastner v. Michael Astrue
697 F.3d 642
7th Cir.2012Background
- Kastner applied for disability benefits under 42 U.S.C. § 423(d) based on degenerative disc disease, spinal stenosis, and chronic nerve damage.
- The ALJ found Kastner’s spine disorder severe but not meeting or equaling a listed impairment, and thus not presumptively disabled.
- Kastner underwent multiple MRIs showing spondylosis, herniated discs, stenosis, and later surgeries aimed at cervical disc removal.
- Post-surgery, Kastner experienced variable outcomes including pain relief in some areas but persistent or recurrent symptoms.
- State agency and treating physicians offered conflicting assessments of Kastner’s functional capacity, with some deeming sedentary work possible and others noting significant limitations.
- The district court affirmed the ALJ’s decision; on appeal, the Seventh Circuit held the ALJ inadequately explained why Kastner did not meet listing 1.04(A) or (C) and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ adequately explained listing 1.04(A) analysis | Kastner argues ROM evidence shows 1.04(A) criteria met | Kastner’s motion evidence insufficient; ALJ relied on incomplete analysis | Remand required for proper listing discussion |
| Whether substantial evidence supports avoiding presumptive disability under 1.04 | Evidence of limited spinal motion and motor loss supports Listing 1.04(A) | Evidence insufficient or not properly connected to 1.04 criteria | Remand required to reassess under correct framework |
| Whether the ALJ’s reasoning violated Chenery/adequate evidentiary bridge | ALJ failed to anchor conclusions in the record; relied on mischaracterized references | Commissioner asserts alternative rationale not properly adopted by ALJ | Remand to allow proper articulation of the reasoning |
Key Cases Cited
- Craft v. Astrue, 539 F.3d 668 (7th Cir. 2008) (require an accurate, logical bridge between evidence and conclusion)
- Barnett v. Barnhart, 381 F.3d 664 (7th Cir. 2004) (must discuss the listing by name with more than a perfunctory analysis)
- Chenery Corp. v. SEC, 318 U.S. 80 (Supreme Court 1943) (agency may not defend decision on grounds not embraced by agency)
- Steele v. Barnhart, 290 F.3d 936 (7th Cir. 2002) (remedies when decision is poorly articulated or lacks evidentiary support)
- Myles v. Astrue, 582 F.3d 672 (7th Cir. 2009) (requirement to consider all relevant medical evidence without selective review)
- Parker v. Astrue, 597 F.3d 920 (7th Cir. 2010) (illustrates limits of appellate defenses not embraced by ALJ)