Christine Bjornson v. Michael Astru
2012 U.S. App. LEXIS 1790
| 7th Cir. | 2012Background
- Bjornson suffered a 1999 auto accident leading to Chiari malformation and hydrocephalus, requiring multiple brain/spine surgeries and heavy pain medication.
- She was last insured for Social Security disability benefits in June 2005, creating a last-insured-date threshold for eligibility.
- The record includes pre- and post-June 2005 medical evidence with headaches, back pain, visual issues, speech problems, and treatment by several doctors.
- The ALJ concluded she could perform sedentary work with sit/stand flexibility, based on a vocational expert’s assessment.
- The court reversed and remanded, faulting boilerplate credibility language, misweighting of medical opinions, and improper integration of credibility with residual functional capacity.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credibility boilerplate improper | Bjornson argues template language misstates credibility findings | SSA relies on standard boilerplate to summarize credibility | Template language rejected; credibility must link to RFC |
| Weight given to post-2005 medical data | Post-last-insured evidence should be considered | Data viewed as irrelevant to pre-2005 disability | Post-2005 data properly considered for ongoing disability assessment |
| Reliance on Dr. Ezike over Rafiq | Ezike’s opinions misaligned with record evidence | Ezike's opinions given appropriate weight | Improper weighting; need coherent link to medical record evidence |
| Assessment of residual functional capacity (RFC) | ALJ failed to bridge medical evidence with RFC | RFC supported by doctors’ reports | RFC assessment insufficiently tied to credibility and medical evidence; remand warranted |
| Handling of daily activities vs. full-time work | Daily activities do not prove ability to sustain work | Some daily activities reflect capabilities | Error in discounting credibility based on daily activities; remand for proper evaluation |
Key Cases Cited
- Parker v. Astrue, 597 F.3d 920 (7th Cir. 2010) (meaningless boilerplate; credibility not clear from mere phrasing)
- Punzio v. Astrue, 630 F.3d 704 (7th Cir. 2011) (credibility must be tied to record evidence)
- Spiva v. Astrue, 628 F.3d 346 (7th Cir. 2010) (credibility assessment must reflect specific record support)
- Hardman v. Barnhart, 362 F.3d 676 (10th Cir. 2004) (boilerplate language insufficient to explain disability finding)
- Ray v. Bowen, 843 F.2d 998 (7th Cir. 1988) (rejects generic credibility assumptions without record support)