Deborah Morgan v. Andrew Saul
994 F.3d 785
7th Cir.2021Background
- Plaintiff applied for disability benefits in 2016, citing heart and back problems, arthritis, neuropathy, and carpal tunnel syndrome.
- An ALJ reviewed extensive medical records (x‑rays, MRIs, consultative exams) and found degenerative changes but no nerve‑root impingement and largely normal neurologic findings.
- The ALJ concluded Plaintiff retained the RFC to perform light work with some additional limitations (e.g., on climbing) and denied benefits.
- Plaintiff appealed, arguing the ALJ selectively ignored evidence of cervical/lumbar disc disease, improperly discounted her symptom statements, and omitted manipulative limitations from the RFC and vocational hypothetical.
- The district court affirmed the ALJ; the Seventh Circuit reviewed de novo but applied the substantial‑evidence standard to the ALJ’s factual findings and affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ ignored a line of evidence re: cervical/lumbar degenerative disease | ALJ selectively reviewed imaging and exam findings and omitted material records showing disabling back/neck problems | ALJ considered the relevant imaging and exams; omitted items were cumulative and did not show a different impairment level | ALJ did not ignore an entire line of evidence; omission of some findings was harmless because addressed evidence supported the RFC |
| Whether ALJ’s credibility assessment of symptom severity was patently wrong | ALJ improperly discounted symptoms, relied on lack of treatment and imaging, and "played doctor" | ALJ permissibly relied on objective studies, conservative treatment, normal strength/gait, and Plaintiff’s own reports when assessing credibility | Credibility finding upheld as supported by specific, record‑based reasons and not patently wrong |
| Whether ALJ improperly based adverse credibility on daily activities | Plaintiff argued her limited activities (leaning on cart, doing one room at a time) don’t equate to work ability | ALJ used daily activities only to evaluate consistency with alleged limitations and did not equate them to full‑time work | Use of daily activities as one piece of the credibility analysis was proper and not reversible |
| Whether ALJ erred by omitting manipulative (hand) limitations from RFC/hypothetical | Plaintiff contends carpal tunnel and hand problems require manipulative limits that should be included | Record contained no treating/examining opinion imposing manipulative restrictions; some providers labeled CTS "severe" but found no manipulative limits | ALJ reasonably declined to include manipulative limitations because the medical record did not support them |
Key Cases Cited
- Skinner v. Astrue, 478 F.3d 836 (7th Cir. 2007) (standard of review for ALJ decisions)
- Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (definition of substantial evidence)
- Jones v. Astrue, 623 F.3d 1155 (7th Cir. 2010) (ALJ need not discuss every record item but cannot ignore an entire line of evidence)
- Pepper v. Colvin, 712 F.3d 351 (7th Cir. 2013) (credibility and RFC discussion requirements)
- Indoranto v. Barnhart, 374 F.3d 470 (7th Cir. 2004) (ALJ must confront and explain rejected evidence)
- Prochaska v. Barnhart, 454 F.3d 731 (7th Cir. 2006) (ALJ may consider objective evidence and treatment in credibility assessment)
- Plessinger v. Berryhill, 900 F.3d 909 (7th Cir. 2018) (example of ALJ "playing doctor" when misreading a physician's opinion)
- Yurt v. Colvin, 758 F.3d 850 (7th Cir. 2014) (ALJ must include all limitations supported by the record in RFC/hypotheticals)