Daniel Hall v. Carolyn Colvin
778 F.3d 688
| 7th Cir. | 2015Background
- Hall applied for social security disability benefits in 2010, after decade-long pain from ankle, back, and knee injuries and related conditions.
- The ALJ found Hall not totally disabled but severely impaired by ankle ligament tear, obesity, and knee meniscus tear.
- Hall’s VA rating was 70% disabled with a finding of total unemployability by the VA, which the ALJ acknowledged but deemed not controlling due to SSA criteria.
- Diagnostic evidence included multiple imaging studies showing various issues; MRI evidence (particularly MRI after the hearing) emerged but did not influence the decision.
- The ALJ discounted Hall’s testimony and some doctor opinions, and stressed the lack of objective diagnostic confirmation via imaging as justification to deny total disability.
- The district court denied review, and the case was appealed to the court, which reversed and remanded for new proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credibility and need for objective tests for pain | Hall's pain credible; lack of MRI should not bar benefits per SSR 96-7p. | ALJ properly required objective testing to support pain claims. | Remand required; error in denying benefits without adequate evidence. |
| Weight given to VA disability determination | VA finding of total unemployability supports SSA disability. | SSA and VA criteria differ; VA finding not controlling. | Remand; the ALJ inadequately weighed the VA determination. |
| Use of MRI and medical opinions | Earlier MRIs showed problems; ALJ should have ordered MRI or consulted medical expert. | Existing medical opinions and tests provide enough basis for decision. | Remand; failure to obtain MRI and to analyze medical evidence undermines substantial evidence. |
Key Cases Cited
- McCartey v. Massanari, 298 F.3d 1072 (9th Cir. 2002) (pain criteria and SSA disability interpretation)
- Pierce v. Colvin, 739 F.3d 1046 (7th Cir. 2014) (credibility and lack of objective evidence for pain not fatal to credibility)
- Carradine v. Barnhart, 360 F.3d 751 (7th Cir. 2004) (objective evidence not sole basis to deny pain claims)