Crane v. Commissioner of Social Security
3:09-cv-00922
S.D. Ill.Dec 1, 2010Background
- Crane appeals a final SSA decision denying disability benefits after ALJ concluded he is not disabled.
- Crane’s alleged impairments include degenerative joint disease of the spine, depression, and PTSD; evidence spans 2005–2008 medical records and VA disability materials.
- The ALJ applied the five-step sequential analysis and found Crane unable to perform past work but able to perform other medium work with limited public contact.
- Jobs identified as available in the national economy: food preparer and packager, both involving simple tasks and no public contact.
- Dr. Bloos, a psychologist, diagnosed PTSD and dysthymia with low GAF; her findings were considered but not fully reconceived by the ALJ.
- Crane argued various procedural and evidentiary errors, including failure to credit Dr. Bloos’s opinion, but the court ultimately affirmed the ALJ’s determination.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly weighed medical opinion evidence | Crane asserts BOLOS report merits greater weight | ALJ considered evidence and discussed relevant records | ALJ properly weighed evidence and found impairments supported |
| Whether the ALJ erred in independent medical assessment | Crane claims ALJ substituted own opinion at hearing | Record supported reliance on objective evidence | No reversible error; appearance at hearing limited impact |
| Whether Crane meets Listing 12.06 for PTSD/anxiety | PTSD meets A and B criteria based on GAF scores | Record shows only mild to moderate functional limits; no marked deficits | Listing not met; substantial evidence supports decision |
| Whether the ALJ properly applied the five-step framework | Crane cannot perform other work due to impairments | There exists a significant number of jobs Crane can perform | Proper application; denial upheld |
Key Cases Cited
- Clifford v. Apfel, 227 F.3d 863 (7th Cir. 2000) (sequence of five-step inquiry governs disability determinations)
- Young v. Barnhart, 362 F.3d 995 (7th Cir. 2004) (burden shifts to Commissioner at step 4)
- Skinner v. Astrue, 478 F.3d 836 (7th Cir. 2007) (substantial evidence standard defines review)
- Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (medical evidence must support disability findings)
- Jens v. Barnhart, 347 F.3d 209 (7th Cir. 2003) (courts defer to ALJ credibility determinations)
- Schmidt v. Astrue, 496 F.3d 833 (7th Cir. 2007) (need for coherent path of reasoning in medical evidence)
- Herron v. Shalala, 19 F.3d 333 (7th Cir. 1994) (ALJs must weigh all credible medical evidence)
- Edwards v. Sullivan, 985 F.2d 334 (7th Cir. 1993) ( articulation standard for evidence in disability reviews)
- Powers v. Apfel, 207 F.3d 431 (7th Cir. 2000) (credibility can be based on appearance and testimony)
- Scivally v. Sullivan, 966 F.2d 1070 (7th Cir. 1992) (avoid unilateral medical determinations by ALJ)