Debra Prill v. Kilolo Kijakazi
23 F.4th 738
| 7th Cir. | 2022Background
- Prill worked as a county highway maintenance worker until she retired in August 2014 and then applied for Social Security disability benefits alleging inability to perform medium/heavy work due to chronic back, neck, and knee pain.
- Medical records from 2014–2016 were mixed: some treating notes showed conservative treatment and periods of improvement; two independent medical exams (Kulwicki, Monacci) found limited knee restrictions and no permanent spine restrictions; treating physician Dr. Bodeau and consultative examiner Dr. Marozava reported greater limitations.
- The ALJ found Prill’s symptom testimony only partially credible, noting the alleged onset coincided with planned retirement, conservative treatment, improvement with medications/therapy, and Prill’s daily activities (e.g., gardening, household chores).
- The ALJ gave little weight to Dr. Bodeau and Dr. Marozava (finding their opinions largely driven by subjective complaints) and gave greater weight to consultative and state-agency opinions, producing an RFC for medium work with several postural and environmental limits.
- The ALJ concluded Prill could not return to past relevant work but could perform other jobs in the national economy; the Appeals Council denied review, the district court affirmed, and the Seventh Circuit likewise affirmed.
Issues
| Issue | Prill's Argument | Commissioner/ALJ's Argument | Held |
|---|---|---|---|
| Whether ALJ properly evaluated Prill's subjective symptom allegations (credibility, timing of onset) | Prill: ALJ erred by discounting her testimony, giving insufficient weight to her long work history, and improperly relying on timing of retirement | ALJ: onset coincided with planned retirement; medical records, conservative treatment, medication response, and daily activities undercut claimed severity | Held: AFFIRMED — substantial evidence supports ALJ's credibility findings and consideration of timing and daily activities |
| Whether ALJ erred in rejecting treating physician Dr. Bodeau's opinion | Prill: ALJ should have given controlling/greater weight to Bodeau's restrictions | ALJ: Bodeau's opinion contradicted his own notes and objective record; lacked supporting diagnostic testing | Held: AFFIRMED — ALJ permissibly discounted Bodeau as internally inconsistent and inconsistent with record |
| Whether ALJ properly weighed consultative and state-agency opinions (Kulwicki, Monacci, Chan) | Prill: ALJ failed to account fully for IME findings and spine issues | ALJ: consulted physicians’ opinions were consistent with objective findings and supported RFC restrictions | Held: AFFIRMED — ALJ reasonably credited consultative/state-agency opinions and incorporated appropriate limits |
| Whether ALJ properly considered effect of pain medications on functioning | Prill: medication enabled mere functioning, not medium work; side effects/ongoing pain not adequately considered | ALJ: record shows medications controlled symptoms with good results and no problematic side effects | Held: AFFIRMED — substantial evidence supports ALJ’s conclusion that medications sufficiently managed symptoms for the RFC |
Key Cases Cited
- Biestek v. Berryhill, 139 S. Ct. 1148 (U.S. 2019) (explains substantial-evidence standard in disability reviews)
- L.D.R. v. Berryhill, 920 F.3d 1146 (7th Cir. 2019) (standard for appellate review of ALJ findings)
- Karr v. Saul, 989 F.3d 508 (7th Cir. 2021) (substantial-evidence review; claimant burden)
- Butler v. Kijakazi, 4 F.4th 498 (7th Cir. 2021) (summary of five-step disability evaluation)
- Loveless v. Colvin, 810 F.3d 502 (7th Cir. 2016) (work history is one credibility factor, not dispositive)
- Denton v. Astrue, 596 F.3d 419 (7th Cir. 2010) (ALJ may decline to assign a claimant preferred weight to specific evidence)
- Zoch v. Saul, 981 F.3d 597 (7th Cir. 2020) (permissible to give less weight to treating opinion inconsistent with objective record)
- Ketelboeter v. Astrue, 550 F.3d 620 (7th Cir. 2008) (when physician opinions lack objective support, ALJ may discount them)