Davis v. Commissioner of Social Security
1:23-cv-00519
N.D. Ind.Nov 15, 2024Background
- Jeromy Davis applied for disability insurance benefits under Title II of the Social Security Act, alleging disability from back pain and depression since September 2018.
- His claims were denied at initial review, by an Administrative Law Judge (ALJ), and upon appeal to the Appeals Council; the District Court previously remanded for further proceedings.
- Following remand, Davis's claims were consolidated and the ALJ again denied benefits, finding he was capable of performing light work with certain limitations.
- The ALJ relied on state agency physician opinions dated before key 2020 imaging and on selective medical and physical therapy records, concluding Davis's symptoms were not disabling.
- Davis appealed to the District Court, focusing on the ALJ’s failure to submit new medical imaging to an expert, failure to consider relevant physical therapy records, and reliance on a vocational expert’s job numbers.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Failure to Submit 2020 Imaging | ALJ ignored critical new MRI/X-ray evidence and "played doctor" by interpreting it herself. | 2020 imaging was not substantially different; plaintiff had burden to provide more. | Remand; ALJ must seek expert review of imaging |
| Ignoring Physical Therapy Evidence | ALJ ignored physical therapy notes showing greater impairment, omitting material evidence. | Defendant failed to respond (waiver). | Remand; ALJ must address these records |
| Unreliable Vocational Methodology | Vocational Expert’s (VE) job number estimates were methodologically unsound. | Defendant defended the VE’s methods. | Not reached/decided (case remanded earlier) |
| Burden of Proof on Evidence/Opinions | Plaintiff not required to submit additional medical opinion, only medical evidence. | Plaintiff failed to provide supporting medical opinions as required by regulations. | Plaintiff’s burden is medical evidence, not opinion |
Key Cases Cited
- Richardson v. Perales, 402 U.S. 389 (1971) (defining "substantial evidence" in Social Security appeals)
- Schomas v. Colvin, 732 F.3d 702 (7th Cir. 2013) (district court reviews ALJ as Commissioner’s final decision)
- Craft v. Astrue, 539 F.3d 668 (7th Cir. 2008) (substantial evidence review standard for denial of benefits)
- Goins v. Colvin, 764 F.3d 677 (7th Cir. 2014) (ALJ may not interpret new medical evidence without expert review)
- Terry v. Astrue, 580 F.3d 471 (7th Cir. 2009) (ALJ must provide a logical bridge from evidence to conclusions)
- Lopez ex rel. Lopez v. Barnhart, 336 F.3d 535 (7th Cir. 2003) (court cannot reweigh evidence or decide credibility)
- Zurawski v. Halter, 245 F.3d 881 (7th Cir. 2001) (ALJ must not ignore an entire line of contrary evidence)
- Elder v. Astrue, 529 F.3d 408 (7th Cir. 2008) (affirmation where there is adequate support, even if reasonable minds could differ)