48 F.4th 769
7th Cir.2022Background
- Donna Jarnutowski applied for Social Security disability benefits based on a chronic right-foot condition (multiple surgeries, most recent in Feb. 2015), neck/leg pain, obesity, and mental health issues.
- The ALJ found a closed period of disability from Sept. 11, 2013 through Jan. 18, 2016, during which Jarnutowski was limited to light work with restrictions; after Jan. 19, 2016 the ALJ concluded medical improvement allowed full-range medium work.
- The ALJ relied largely on post‑surgery treatment notes showing ability to walk, normal exam findings, lack of further orthopedic follow‑up after 2016, and improvement statements from treating providers; the ALJ discredited Jarnutowski’s testimony and gave no weight to her treating orthopedist Dr. Kelikian’s functional opinion.
- Agency consultants found severe joint dysfunction but said the record was insufficient to determine function; Dr. Kelikian’s August 2016 form limited lifting/carrying, walking/standing time, and required leg elevation; claimant testified continued limits on lifting/carrying and standing/walking after surgery.
- The Appeals Council denied review; the district court affirmed the ALJ; the Seventh Circuit reversed and remanded, holding the ALJ failed to build a logical bridge explaining how claimant could meet medium‑work lifting/carrying requirements and inadequately explained discrediting the key evidence.
- A dissent would have affirmed, arguing the ALJ’s discussion of longitudinal improvement and normal post‑surgery exams was sufficient and that the claimant bears the burden to prove continued disability.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ adequately supported post‑surgery RFC finding of full‑range medium work | ALJ failed to explain how claimant could lift/carry up to 50 lbs and frequently 25 lbs after surgery | ALJ cited improved gait, normal exams, reduced treatment, and activity as tolerated to support RFC | Reversed: ALJ did not build a logical bridge showing claimant could meet medium‑work lifting/carrying requirements |
| Whether ALJ properly rejected claimant's subjective symptom testimony | Claimant testified persistent limits (lifting, carrying, standing, walking); ALJ’s boilerplate credibility language insufficient | ALJ pointed to activities, normal exams, and reduced treatment as inconsistent with claimant’s statements | Reversed: ALJ’s credibility rejection inadequately explained and inconsistent with objective findings supporting complaints |
| Whether ALJ permissibly discounted treating physician Dr. Kelikian’s RFC opinion | Dr. Kelikian provided detailed functional limits consistent with records; ALJ failed to point to specific longitudinal evidence contradicting his opinion | ALJ said treating opinion was inconsistent with longitudinal record and post‑2016 findings | Reversed: ALJ did not adequately articulate why treating opinion was rejected or identify record evidence that contradicted it |
| Remedy — is remand required? | Remand for further proceedings to explain RFC and reassess evidence | Commissioner urged affirmance | Remanded to SSA for further proceedings consistent with opinion |
Key Cases Cited
- Butler v. Kijakazi, 4 F.4th 498 (7th Cir. 2021) (ALJ must build a logical bridge from evidence to conclusions)
- Elder v. Astrue, 529 F.3d 408 (7th Cir. 2008) (very deferential standard of review for ALJ findings)
- Gedatus v. Saul, 994 F.3d 893 (7th Cir. 2021) (scope of review and burden at RFC stage)
- Briscoe ex rel. Taylor v. Barnhart, 425 F.3d 345 (7th Cir. 2005) (failure to explain RFC conclusions warrants reversal)
- Jeske v. Saul, 955 F.3d 583 (7th Cir. 2020) (SSR 96‑8p requirements and when remand is required)
- Spicher v. Berryhill, 898 F.3d 754 (7th Cir. 2018) (may affirm if ALJ builds accurate logical bridge)
- Murphy v. Colvin, 759 F.3d 811 (7th Cir. 2014) (improvement must be sufficient to meet legal criteria; walking ability alone insufficient)
- Minnick v. Colvin, 775 F.3d 929 (7th Cir. 2015) (boilerplate credibility language is inadequate without specific reasons)
- Lothridge v. Saul, 984 F.3d 1227 (7th Cir. 2021) (RFC analysis must enable review of totality of claimant’s limitations)
- Reinaas v. Saul, 953 F.3d 461 (7th Cir. 2020) (distinguishing daily activities from ability to perform full‑time work)
- Bjornson v. Astrue, 671 F.3d 640 (7th Cir. 2012) (limitations in daily living do not necessarily translate to ability to work full time)
- Jozefyk v. Berryhill, 923 F.3d 492 (7th Cir. 2019) (ALJ must tie record evidence to RFC limitations)
- Summers v. Berryhill, 864 F.3d 523 (7th Cir. 2017) (claimant bears burden to prove disability at RFC stage)