Garcia v. Colvin
2013 U.S. App. LEXIS 25452
7th Cir.2013Background
- Plaintiff Garcia applied for social security disability in 2010 at age 40, alleging disability from cirrhosis, severe thrombocytopenia, hepatitis C, and an umbilical hernia, all linked to alcoholism which he stopped in 2010.
- An administrative law judge (ALJ) ruled Garcia could perform sedentary work with limitations and denied benefits.
- Two examining doctors, including an agency physician, opined Garcia cannot engage in substantial gainful activity, with one noting cirrhosis as a transplant candidate and low platelets complicating procedures.
- Garcia’s pain and other ailments led to repeated hospitalizations; he reportedly has significant daily pain and fatigue and substantial functional limitations.
- Garcia’s fiancée testified to nighttime pain, which the ALJ gave only limited weight due to bias concerns.
- The Seventh Circuit reversed the district court, faulting the ALJ’s reasoning, misquoting of medical opinions, bias handling, and reliance on weak credibility and partial medical conclusions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly weighed medical opinions | Garcia’s treating and agency doctors say disability; ALJ erred in discounting them. | ALJ can partially discount medical opinions based on overall administrative record. | Remand required; errors in weighing medical opinions. |
| Whether the ALJ properly credited credibility and lay testimony | Fiancée’s testimony and Garcia’s pain were not adequately weighed and there was bias in discounting. | Some credibility concerns are within the ALJ’s discretion. | Remand required; credibility determination flawed. |
| Whether the ALJ properly evaluated Garcia’s residual functional capacity and disability status under the medical listings | Garcia’s condition fits severe impairments and cannot support sedentary work without mischaracterization. | RFC and listing analysis supported by medical evidence were adequate. | Remand required; RFC and listing analysis insufficient. |
Key Cases Cited
- Bjornson v. Astrue, 671 F.3d 640 (7th Cir.2012) (medical opinions relevant to disability determinations; conflict with reserved issues)
- Ferguson v. Commissioner of Social Security, 628 F.3d 269 (6th Cir.2010) (disability determination requires more than medical opinions)
- Gentle v. Barnhart, 430 F.3d 865 (7th Cir.2005) (employer's conduct may reflect disability; not determinative)
- Hawkins v. First Union Corp. Long-Term Disability Plan, 326 F.3d 914 (7th Cir.2003) (employer decisions and accommodation can affect disability status)
- Wilder v. Apfel, 153 F.3d 799 (7th Cir.1998) (credibility and evaluation of pain properly guarded)
- Kelley v. Callahan, 133 F.3d 583 (8th Cir.1998) (evaluation of medical evidence and disability standard)
- Parker v. Astrue, 597 F.3d 920 (7th Cir.2010) (credibility and boilerplate language under scrutiny)
- Shauger v. Astrue, 676 F.3d 690 (7th Cir.2012) (SSR 96-7p and absence of treatment as credibility factor)
- Craft v. Astrue, 539 F.3d 668 (7th Cir.2008) (need for careful consideration of medical evidence and non-medical factors)
- Blakeman v. Astrue, 509 F.3d 878 (8th Cir.2007) (malingering and insurance status considerations in credibility)
- Orn v. Astrue, 495 F.3d 625 (7th Cir.2007) (role of medical evidence in disability determinations)