Dixon v. Commissioner of Social Security
2:12-cv-00464
N.D. Ind.Mar 7, 2014Background
- Dixon, a 43-year-old woman with high school education, seeks SSA disability benefits (DIB/SSI) with onset date Jan 22, 2009; ALJ denied benefits May 26, 2011; Appeals Council denied review Sept 19, 2012; this suit challenges that denial; substantial materials include medical records showing diabetes with neuropathy, obesity, retinopathy, carpal tunnel, back issues, and psychiatric conditions; VE testimony indicated Sears job was semi-skilled with lifting and standing requirements; ALJ found RFC for sedentary work with various limitations; party consent to magistrate judge; final decision is reviewed under 42 U.S.C. § 405(g).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credibility of plaintiff’s testimony | ALJ failed to connect daily activities to claimed limitations | ALJ could consider daily activities in credibility assessment | Remand required for missing logical bridge between testimony and conclusions |
| Consideration of treatment history under SSR 96-7p | ALJ erred by inferring non-disabling impairment from lack of treatment | Record supported credibility with observed symptoms and treatment notes | Remand required to address SSR 96-7p explanations |
| Obesity impact on RFC | ALJ did not assess obesity impact on RFC as required | Obesity discussed but not fully integrated into RFC | Remand required to discuss obesity effects on RFC |
| Reliance on Dr. Brill’s opinion | ALJ gave limited weight to Dr. Brill’s findings | Dr. Brill’s review supported certain RFC aspects | Clarification on remand for Dr. Brill’s role warranted |
| Overall sufficiency of RFC articulation | ALJ failed to provide a logical bridge for several findings | RFC supported by record overall | Remand for complete RFC articulation |
Key Cases Cited
- Shideler v. Astrue, 688 F.3d 306 (7th Cir. 2012) (deference to credibility; need for adequate explanation of credibility findings)
- Prochaska v. Barnhart, 454 F.3d 731 (7th Cir. 2006) (need for logical bridge between evidence and disability decision)
- Scott v. Barnhart, 297 F.3d 589 (7th Cir. 2002) (ALJ must build a logical bridge linking evidence to conclusions)