Daniel Minnick v. Carolyn Colvin
2015 U.S. App. LEXIS 249
| 7th Cir. | 2015Background
- Minnick, suffering from fibromyalgia, COPD, and degenerative disc disease, applied for Social Security disability benefits in 2010.
- DDB denied his claim; an ALJ held Minnick not disabled; Appeals Council denied review; decision became final for review.
- District court affirmed; the Seventh Circuit reverses and remands for further proceedings due to multiple errors.
- Medical record shows long-standing pain with imaging evidence of disc disease; various doctors noted limitations and functional impairment.
- ALJ found a residual functional capacity (RFC) limiting lifting, standing, and other activities, and relied on some but not all treating/reviewing physicians' opinions.
- VE testified Minnick could perform several unskilled, sedentary jobs; the ALJ relied on that to conclude non-disability at step five.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did the ALJ adequately analyze Listing 1.04? | Minnick argues the ALJ failed to justify why combined impairments did not meet/equal Listing 1.04. | Commissioner contends no listing was met and the ALJ properly assessed evidence. | Remand for further Listing 1.04 analysis required. |
| Is the RFC supported by substantial evidence given credibility and treating-source opinions? | Minnick contends the RFC is not supported due to improper credibility analysis and discounting Dr. Kachmann. | Commissioner asserts the RFC is supported by the record and by other medical opinions. | Remand to reevaluate credibility and treating-source weight warranted. |
| Did the ALJ improperly discount Dr. Kachmann's treating-opinion on bending/twisting? | Minnick argues the ALJ lacked adequate explanation for discounting Kachmann's opinions and failed to relate them to the record. | Commissioner claims inconsistency in Kachmann's opinions justified limited weight. | ALJ must reevaluate Kachmann's findings and provide proper justification. |
| Did the ALJ fail to build a logical bridge from evidence to conclusion in credibility/weight determinations? | Minnick asserts the ALJ's boilerplate credibility language and missing discussion of objective signs undermines the decision. | Commissioner contends the ALJ considered evidence and medical signs in context. | Remand to articulate reasoning and link evidence to conclusions. |
Key Cases Cited
- Barnett v. Barnhart, 381 F.3d 664 (7th Cir. 2004) (must discuss listing by name with more than perfunctory analysis)
- Kastner v. Astrue, 697 F.3d 642 (7th Cir. 2012) (cursory listing analysis inadequate; require meaningful review)
- Brindisi v. Barnhart, 315 F.3d 783 (7th Cir. 2003) (lack of meaningful listing analysis reversible)
- Roddy v. Astrue, 705 F.3d 631 (7th Cir. 2013) (explain why treating-opinion is rejected; justify weight)
- Schmidt v. Barnhart, 395 F.3d 737 (7th Cir. 2005) (must build a logical bridge from evidence to conclusion)
- Clifford v. Apfel, 227 F.3d 863 (7th Cir. 2000) (ptctrine that credibility requires support from medical signs)
- Craft v. Astrue, 539 F.3d 668 (7th Cir. 2008) (credibility determinations must be well-explained)
- Murphy v. Astrue, 496 F.3d 630 (7th Cir. 2007) (duty to fully develop the record and explain analysis)