Childress v. Colvin
845 F.3d 789
7th Cir.2017Background
- Childress (applied 2008 at age 35) sought Social Security disability benefits; denied after two ALJ hearings (2010, 2013) and affirmed by district court; appeal to Seventh Circuit followed.
- Treating cardiologist (Dr. Addai) and treating physician (Dr. Hartman) diagnosed serious cardiac and pulmonary conditions (congestive heart failure, cardiomyopathy, COPD/asthma), low ejection fractions (as low as 20–25%), severely dilated left ventricle (>6 cm), obesity, edema, and related symptoms; treatments and tests spanned multiple years.
- Treating physicians opined severe functional limits (e.g., total sitting/standing/walking in an 8‑hour day well below full‑time work; need to lie down during day; likely worsening with work; total disability).
- Two nonexamining state agency physicians, reviewing an incomplete record, concluded claimant could sit ~6 hours and stand/walk ~6 hours; ALJ relied on a restrictive sedentary RFC rather than treating opinions.
- ALJ discounted treating physicians’ opinions and claimant’s credibility based on perceived inconsistencies (e.g., walking 30 minutes daily, brief part‑time work, living alone) and absence of certain objective signs; ALJ found claimant capable of limited sedentary work. Seventh Circuit reversed and remanded.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight to treating physicians’ opinions | Treating doctors’ detailed records and combined‑impairment assessments entitle them to significant weight; ALJ erred in discounting them | ALJ found inconsistencies between physicians’ notes, claimant’s activities, and medical record supporting discounting | Court: ALJ gave treating opinions virtually no weight improperly; remand required to give proper consideration to treating evidence |
| Credibility of claimant | Testimony about daily limitations, need to lie down, reliance on family support is credible and consistent with medical record | ALJ pointed to walking, brief part‑time work, living alone and smoking cessation timing to discount credibility | Court: ALJ’s reasons were inadequate or based on feeble inferences; credibility findings not supported; remand required |
| RFC evaluation (sitting/standing/walking limits) | Treating opinions and objective tests show claimant cannot meet sedentary work thresholds (6 hrs sit/2 hrs stand) and needs breaks/absences | ALJ adopted an RFC allowing limited sedentary work (sitting 6 hrs, standing/walking 2 hrs) and limited restrictions | Court: ALJ’s RFC findings inconsistent with treating opinions and vocational expert testimony about absenteeism; RFC unsupported; remand required |
| Consideration of objective findings and combined impairments | ALJ failed to account for relevant objective evidence (e.g., LV >6 cm) and improperly treated impairments in isolation | ALJ relied on parts of record and selective evidence to minimize severity | Court: ALJ overlooked and misstated material objective findings and failed to properly assess combined effects; remand directed |
Key Cases Cited
- Engstrand v. Colvin, 788 F.3d 655 (7th Cir. 2015) (treating physicians should be assessed on combined impairments; activities of daily living differ from work capacity)
- Bjornson v. Astrue, 671 F.3d 640 (7th Cir. 2012) (household activities and sporadic work are not inconsistent with inability to perform substantial gainful activity)
- Meuser v. Colvin, 838 F.3d 905 (7th Cir. 2016) (per curiam) (treating source opinions ordinarily deserve significant weight under the regulations)
- Shramek v. Apfel, 226 F.3d 809 (7th Cir. 2000) (considerations about claimant’s smoking and its relevance to credibility/impairment require evidentiary support)
Outcome: Judgment reversed; case remanded to district court with directions to remand to the Social Security Administration for further proceedings consistent with opinion.