Chic Zoch v. Andrew Saul, 981 F.3d 597

Plaintiff Chic Zoch applied for Title II disability benefits, alleging debilitating back, leg, and hand pain; insured through December 31, 2013.
Four treating physicians evaluated her: Dr. Paluska (opined she could not do sedentary work), Dr. Lee, Dr. Harms, and Dr. Rauther; three of these treating doctors (Lee, Harms, Rauther) reported largely normal strength, gait, and objective testing and did not recommend surgery.
A consultative SSA reviewer, Dr. Robinson, found the objective record did not support disabling limitations and assigned an RFC allowing six hours of sitting (light/sedentary work); later treating opinions post-dating the insured period were more restrictive.
At hearing Zoch testified she could not sit or stand more than ~15 minutes, needed help with many daily tasks, and used a cane much of the time; her written application and some treating notes reported more independent daily activities.
The ALJ credited Robinson and three treating doctors, gave little weight to Dr. Paluska (because his opinion conflicted with objective evidence, other doctors, and relied on claimant’s subjective report), found Zoch could perform sedentary work with frequent hand use (including her past purchasing-agent job), and denied benefits; the Appeals Council and district court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ improperly discounted Zoch's symptom testimony	Zoch says the ALJ wrongly rejected her testimony about incapacitating pain and functional limits	ALJ relied on inconsistencies with objective tests, treating notes, and Zoch's earlier statements; may assess credibility	ALJ's credibility finding was supported by substantial evidence and not "patently wrong"; affirmed
Whether ALJ erred in rejecting treating Dr. Paluska and finding RFC to sit six hours and use hands frequently	Zoch contends the ALJ failed to give adequate reasons for discounting Paluska, a treating physician, and thus improperly assessed RFC (sitting and manipulative limits)	ALJ gave valid reasons: Paluska conflicted with other treating physicians, consultative examiner, objective tests, and relied on claimant's discredited complaints; post-insured opinions were properly excluded	ALJ properly discounted Paluska and explained RFC; substantial evidence supports finding Zoch can sit six hours and use hands frequently; affirmed

Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (standard for substantial-evidence review)
Summers v. Berryhill, 864 F.3d 523 (7th Cir. 2017) (deference to ALJ credibility determinations unless patently wrong)
Pepper v. Colvin, 712 F.3d 351 (7th Cir. 2013) (ALJ may consider objective evidence and inconsistencies when assessing pain complaints)
Ketelboeter v. Astrue, 550 F.3d 620 (7th Cir. 2008) (consulting examiner’s report may justify discounting a treating opinion that conflicts with objective evidence)
Bates v. Colvin, 736 F.3d 1093 (7th Cir. 2013) (treating physician opinion may be discounted when inconsistent with record)
Liskowitz v. Astrue, 559 F.3d 736 (7th Cir. 2009) (post-period treating opinions may be considered only if they offer a retrospective diagnosis supported by evidence from the insured period)
L.D.R. v. Berryhill, 920 F.3d 1146 (7th Cir. 2019) (court will not reweigh evidence or substitute its judgment for ALJ)