Jennifer Karr v. Andrew Saul, 989 F.3d 508

Jennifer Karr applied for Social Security disability benefits for chronic lower-back pain originating from a past car accident; multiple MRIs showed degenerative disc disease.
Treated by neurosurgeon Isa Canavati (examined 2012 and 2017); underwent conservative treatments (PT, injections, opioids) and had spinal fusion in January 2018 on Canavati’s recommendation.
In November 2017 Canavati wrote that Karr “cannot sit, stand or walk for any sustained period of time,” reporting increasing pain and sleep interruption; Karr testified at the ALJ hearing she must change position every 15–20 minutes.
Agency examiners and two reviewing doctors found Karr could do light/sedentary work and could sit/stand about six hours in an eight-hour day; some contemporaneous notes showed normal strength and gait.
ALJ gave Canavati’s letter only “partial weight,” finding the extreme limitation inconsistent with other objective exam findings, and concluded Karr retained the RFC for sedentary work; the district court affirmed.
On appeal Karr argued the ALJ improperly discounted the treating neurosurgeon’s opinion; the Seventh Circuit affirmed, finding substantial evidence supported the ALJ’s decision and any procedural omission was harmless.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ erred by not giving controlling weight to treating neurosurgeon Canavati’s statement that Karr “cannot sit, stand or walk for any sustained period.”	Canavati is a treating specialist; his statement should receive controlling weight under the pre-2017 treating-physician rule.	The statement was ambiguous (may report patient complaints), and contradicts other objective evidence; ALJ reasonably discounted it.	Affirmed — substantial evidence supports ALJ’s decision; any failure to explicitly apply §404.1527(c)(2) factors was harmless.

Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (explaining the substantial-evidence standard)
Reinaas v. Saul, 953 F.3d 461 (7th Cir. 2020) (treating-physician controlling-weight rule for pre-2017 claims)
Bates v. Colvin, 736 F.3d 1093 (7th Cir. 2013) (ALJ need not defer to portions of treating opinion based solely on claimant’s subjective complaints)
Gerstner v. Berryhill, 879 F.3d 257 (7th Cir. 2018) (ALJ should apply the treating-opinion factors)
Yurt v. Colvin, 758 F.3d 850 (7th Cir. 2014) (need to consider length, nature, extent of treatment relationship when weighing treating opinions)
Moss v. Astrue, 555 F.3d 556 (7th Cir. 2009) (same)
Meuser v. Colvin, 838 F.3d 905 (7th Cir. 2016) (remand required for legal error absent harmlessness)
Lambert v. Berryhill, 896 F.3d 768 (7th Cir. 2018) (harmless-error standard for ALJ legal errors)
McKinzey v. Astrue, 641 F.3d 884 (7th Cir. 2011) (reviewer may predict outcome on remand when confident)
Summers v. Berryhill, 864 F.3d 523 (7th Cir. 2017) (claimant bears burden to prove disability)
Zoch v. Saul, 981 F.3d 597 (7th Cir. 2020) (court will not reweigh evidence under substantial-evidence review)