Dawson v. Commissioner of Social Security
2:14-cv-00245
| N.D. Ind. | Sep 21, 2015Background
- Mary Alice Dawson applied for disability insurance benefits and disabled widow’s benefits, alleging disability beginning April 30, 2008; claims were denied and an ALJ denied benefits on Feb. 20, 2013.
- ALJ found Dawson had severe impairments (spinal arthritis, herniated disc, carpal tunnel), assigned an RFC for a limited range of light work, and concluded jobs exist that she can perform.
- Treating physician Dr. Bayne Spotwood (treating Jan–Oct 2012) completed functional questionnaires concluding Dawson could not sustain even sedentary work, would miss >2 days/month, and needed frequent rests.
- The ALJ rejected Dr. Spotwood’s opinion as "not compelling," citing lack of diagnostic testing, no muscle atrophy, treatment limited to NSAIDs/physical therapy, and that the opinion covered only Jan–Oct 2012.
- Dawson challenged the ALJ’s weighing of the treating opinion, the RFC (including consideration of arthritis, obesity, and combined impairments), and the credibility assessment (daily activities and cane use); the district court granted remand and denied an immediate award of benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight to treating physician opinion | ALJ failed to apply the §404.1527(c) factors and improperly rejected Dr. Spotwood’s RFC findings | ALJ relied on perceived inconsistencies and limited treatment period to discount the opinion | Court: ALJ did not adequately address required factors or identify contradictory evidence; remand for proper consideration |
| RFC (arthritis, obesity, combined impairments) | ALJ failed to evaluate arthritis severity, obesity effects, and combined limitations | ALJ implicitly relied on record findings to support a light-work RFC | Court: ALJ erred by not addressing obesity and combined effects and by making unsupported medical inferences; remand required |
| Credibility (daily activities and cane use) | ALJ mischaracterized daily activities and improperly discounted cane use for lack of prescription | ALJ treated activities and lack of prescription as undermining credibility | Court: ALJ overstated activities, failed to account for limitations in how tasks are done, and erred in treating lack of prescription as dispositive; remand for further assessment and—if needed—clarification from treating sources |
| Award of benefits vs. remand | Plaintiff requested immediate award of benefits | Commissioner opposed award, arguing factual issues remain | Court: Remand required for factfinding; award of benefits denied |
Key Cases Cited
- Schaaf v. Astrue, 602 F.3d 869 (7th Cir.) (treating-physician weight rules)
- Punzio v. Astrue, 630 F.3d 704 (7th Cir.) (limits on ALJ rejecting treating opinion)
- Bates v. Colvin, 736 F.3d 1093 (7th Cir.) (RFC and treating-source guidance)
- Arnett v. Astrue, 676 F.3d 586 (7th Cir.) (consider obesity when assessing combined impairments)
- Spiva v. Astrue, 628 F.3d 346 (7th Cir.) (daily activities often poor basis to infer ability to work full time)
- Parker v. Astrue, 597 F.3d 920 (7th Cir.) (no prescription required to validate cane use)
- Blakes ex rel. Wolfe v. Barnhart, 331 F.3d 565 (7th Cir.) (ALJ must not "play doctor")
- Clifford v. Apfel, 227 F.3d 863 (7th Cir.) (need to consider impairments in combination)