25 F.4th 514
7th Cir.2022Background:
- Mandrell, a former U.S. Coast Guard member, developed PTSD and anxiety after being raped in service; the VA initially rated her 100% disabled (later reduced to 70%).
- She applied for Social Security disability benefits limited to the period up to her date last insured (March 31, 2016); the SSA and Appeals Council denied her claim; the district court affirmed.
- ALJ found severe mental impairments (PTSD, anxiety, depressive disorders) but assigned an RFC permitting medium work with restrictions (simple instructions, no public contact, only occasional coworker/supervisor interaction, low-stress setting).
- ALJ gave little weight to the VA psychologist’s October 2015 report (marked limitations) and to a treating physician’s opinion, questioned claimant’s credibility, and rejected some post-insurance-period records as less relevant.
- Vocational expert testimony, based on the ALJ’s hypotheticals, supported availability of certain medium-level jobs; ALJ denied benefits at Step 5.
- Seventh Circuit reversed and remanded: ALJ failed to connect the RFC to the record, inadequately accounted for limitations in concentration/persistence/pace and made improper medical determinations and selective evidentiary findings.
Issues:
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ improperly made medical judgments and discounted medical evidence (including VA findings and treating sources) | Mandrell: ALJ overstepped by rejecting substantial medical opinions without adequate explanation and by "playing doctor." | Commissioner: ALJ permissibly weighed evidence, discounted VA disability rating, and rejected opinions inconsistent with record. | Court: ALJ erred — he did not adequately explain rejection of medical evidence and made determinations beyond his expertise. |
| Whether RFC and hypotheticals failed to account for moderate limitations in concentration, persistence, and pace and trauma triggers (e.g., presence of men) | Mandrell: RFC didn’t capture PTSD-related deficits (panic, triggers, inconsistent functioning) and VE hypotheticals were incomplete. | Commissioner: RFC and VE testimony reflected claimant’s abilities; post-insurance records less probative. | Court: RFC and hypotheticals insufficiently connected to the record; ALJ failed to reconcile limitations with RFC — remand required. |
Key Cases Cited
- Biestek v. Berryhill, 139 S. Ct. 1148 (clarifies "substantial evidence" standard in administrative proceedings)
- Farrell v. Astrue, 692 F.3d 767 (7th Cir.) (appellate standard of review for SSA decisions)
- Butler v. Kijakazi, 4 F.4th 498 (7th Cir. 2021) (burden of proof shifts at Step 5)
- Rohan v. Chater, 98 F.3d 966 (7th Cir. 1996) (ALJs may not "play doctor")
- Myles v. Astrue, 582 F.3d 672 (7th Cir. 2009) (ALJ must consider all relevant medical evidence and not selectively discuss records)
- Clifford v. Apfel, 227 F.3d 863 (7th Cir. 2000) (ALJ must provide reasons when rejecting treating/source opinions)
- Books v. Chater, 91 F.3d 972 (7th Cir. 1996) (ALJ must consider all relevant evidence)