Kathy Stark v. Carolyn Colvin, 813 F.3d 684

Stark, aged 60, applied for disability benefits alleging disabling back/neck/hip pain from degenerative disc disease.
She previously worked over ten years as a GM yard driver earning about $38,000 annually.
Her back pain began in 2000, leading to three surgeries (two fusions, nerve-root procedures) and ongoing opioid use.
Between 2009 and 2012, state doctors and the ALJ evaluated her functional capacity, with conflicting views on her abilities.
The ALJ denied benefits at Step 4, finding her pain not fully credible and that she could perform past work as a driver.
The district court reversed, and Stark appeals for remand based on flawed credibility analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Credibility assessment and reliance on objective evidence	Stark argues the ALJ ignored supportive treatment evidence and physician prognosis.	Stark asserts the ALJ reasonably considered medical records and test results.	Remand for reevaluation of credibility required.
Impact of work history on credibility	Stark’s long work history shows she struggled through pain to work.	Work history not determinative per statute.	ALJ should properly weigh work history in credibility.
Use of boilerplate language in assessing credibility	ALJ’s boilerplate credibility language masks error in analysis.	Boilerplate does not automatically require remand.	Remand to correct credibility analysis.

Carradine v. Barnhart, 360 F.3d 751 (7th Cir. 2004) (pain can be disabling even without objective evidence)
Hall v. Colvin, 778 F.3d 688 (7th Cir. 2015) (pain without identifiable objective cause may be disabling)
Pierce v. Colvin, 739 F.3d 1046 (7th Cir. 2014) (ALJ must consider claimant’s persistent efforts to work)
Spiva v. Astrue, 628 F.3d 346 (7th Cir. 2010) (rejects relying on household tasks to infer ability to work)
Bjornson v. Astrue, 671 F.3d 640 (7th Cir. 2012) (meaningless boilerplate undermines credibility analysis)