Corcoran v. Commissioner of Social Security, 3:16-cv-00641

Plaintiff Tommy Corcoran (50 at hearing) applied for Social Security disability benefits alleging disability from December 1, 2012; ALJ and Appeals Council denied benefits; district court review followed.
Medical issues: diabetes (on insulin pump), degenerative cervical disc disease (cervical fusion performed), and bilateral carpal tunnel syndrome (two surgeries). Plaintiff also reported low blood sugars, back and neck pain, shoulder spasms, and functional limits in his hands.
Work and functional history: prior commercial driving and mechanical work; last worked in 2011. Plaintiff reported limited activities (difficulty dressing, limited walking, lifting about 20 lbs, intermittent yard work, motorcycle work in garage).
ALJ findings: severe impairments—diabetes and degenerative cervical disc disease; carpal tunnel and mental impairments found nonsevere. RFC: light work with limitations (ALJ concluded plaintiff not disabled).
ALJ discounted plaintiff’s subjective symptom claims based on inconsistencies with medical records and activities, evidence of treatment effectiveness (including successful surgeries), and noncompliance with some treatment/medication.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ failed to consider plaintiff’s hearing testimony, rendering the credibility finding unsupported by substantial evidence	Corcoran: ALJ only cited his hearing testimony twice and thus ignored substantial contrary evidence from his testimony; remand required	Commissioner: ALJ considered the same impairments and symptoms from the testimony, weighed them against objective records, and was not required to cite every piece of testimony	Court: ALJ’s credibility determination was supported by substantial evidence and not "patently wrong"; no remand required

Overman v. Astrue, 546 F.3d 456 (7th Cir. 2008) (standard for substantial evidence review)
Skinner v. Astrue, 478 F.3d 836 (7th Cir. 2007) (definition of substantial evidence)
Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (substantial evidence standard precedent)
Murphy v. Colvin, 759 F.3d 811 (7th Cir. 2014) (deference to ALJ credibility findings based on opportunity to observe witnesses)
Powers v. Apfel, 207 F.3d 431 (7th Cir. 2000) (credibility reversal only if finding is patently wrong)
Arnold v. Barnhart, 473 F.3d 816 (7th Cir. 2007) (subjective complaints may be discounted when inconsistent with objective evidence)
Jones v. Astrue, 623 F.3d 1155 (7th Cir. 2010) (claimant must show more than a mere disagreement with ALJ’s conclusions)
Ketelboeter v. Astrue, 550 F.3d 620 (7th Cir. 2008) (court may not reweigh evidence)
Orlando v. Heckler, 776 F.2d 209 (7th Cir. 1985) (ALJ need not provide written evaluation of each piece of evidence)