Hortansia Lothridge v. Andrew Saul, 984 F.3d 1227

Lothridge (born ~1980s) applied for SSDI and SSI in 2013, alleging fibromyalgia and multiple mental and physical impairments; she previously worked as a CNA, daycare worker, cashier, and telemarketer.
Medical record: longstanding mood disorder, PTSD, bipolar I, ADHD/attention deficits, cognitive and memory problems, and chronic pain; treatment was intermittent and she at times stopped medication.
ALJ found several severe mental impairments and assessed "moderate" limitations in concentration, persistence, and pace at step three, but adopted an RFC limiting Lothridge to simple tasks with limited social contact without addressing sustained on‑task ability.
A vocational expert testified that available jobs would require being on task ~90% of the workday, minimal tardiness, and no more than one absence per month.
District court remanded once to develop record on treatment noncompliance; on remand the ALJ again denied benefits; the Seventh Circuit vacated and remanded because the RFC did not account for the earlier step‑three findings about concentration/pace.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether RFC accounted for moderate limitations in concentration, persistence, and pace	Lothridge: ALJ’s RFC (simple tasks, limited interactions) fails to incorporate moderate deficits in sustained attention/pace and need for breaks	Commissioner: No categorical rule requires more restrictions; plaintiff must identify specific additional limitations	Court: RFC insufficiently explained and inconsistent with step‑three finding; remand required to address on‑task/pace limits
Whether ALJ permissibly relied on gaps/noncompliance in treatment	Lothridge: Noncompliance can be a symptom of mental illness and cannot be used against her without analysis	Commissioner: ALJ permissibly noted noncompliance and conservative treatment	Court: ALJ’s opinion did not clearly penalize noncompliance; this was not the primary error and was not reversible here
Whether ALJ improperly cherry‑picked or failed to weigh treating evidence	Lothridge: ALJ overstated limited activities and ignored treating NP/doctor observations of cognitive decline	Commissioner: ALJ reasonably weighed evidence	Court: ALJ selectively relied on certain activities without reconciling contradictory evidence; contributed to inadequate logical bridge

Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (standard of substantial evidence review)
Crump v. Saul, 932 F.3d 567 (7th Cir. 2019) (RFC must incorporate limitations supported by record, including moderate limitations in concentration, persistence, or pace)
Martin v. Saul, 950 F.3d 369 (7th Cir. 2020) (explain how concentration/pace limitations are reflected in RFC; simple-task restriction may be insufficient)
Villano v. Astrue, 556 F.3d 558 (7th Cir. 2009) (ALJ must build a logical bridge from evidence to conclusion)
Parker v. Astrue, 597 F.3d 920 (7th Cir. 2010) (courts may not uphold agency decision on post hoc rationalizations)
Denton v. Astrue, 596 F.3d 419 (7th Cir. 2010) (ALJ may not ignore large portions of the record pointing toward disability)
Winsted v. Berryhill, 923 F.3d 472 (7th Cir. 2019) (ALJ must cite evidence showing claimant can meet vocational benchmarks identified by VE)
Young v. Barnhart, 362 F.3d 995 (7th Cir. 2004) (need to consider work accommodations and limitations like frequent breaks)
SEC v. Chenery Corp., 318 U.S. 80 (1943) (court cannot supply post hoc rationalizations for agency action)
Craft v. Astrue, 539 F.3d 668 (7th Cir. 2008) (ALJ must account for qualifier language when assessing daily activities)