Kenneth Scrogham v. Carolyn Colvin, 765 F.3d 685

Scrogham applied for disability benefits under the Social Security Act alleging progressive back and leg pain and several comorbid conditions (including sleep apnea, hypertension, obesity, diabetes, and prior spinal issues).
The SSA ALJ denied the application, and the Appeals Council denied review, prompting a district-court challenge for judicial review.
The district court affirmed the ALJ, holding the weight given to treating vs. non-treating opinions and credibility findings were supported by substantial evidence.
The Seventh Circuit reversed, finding the ALJ’s methodology flawed for undervaluing treating physicians and misinterpreting evidence of a progressive, time-varying condition.
The court held the ALJ failed to articulate the proper weighting factors for treating-source opinions and engaged in selective evidence weighing (“sound-bite” methodology).
The case was remanded for further proceedings consistent with the opinion, rather than a determination of benefits on the record to date.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly weighed treating versus non-treating medical opinions.	Scrogham argues treating physician Alcorn’s opinions should receive controlling weight.	The ALJ appropriately weighed competing medical opinions, including non-treating sources.	No; remand required for proper consideration of treating opinions.
Whether the ALJ’s credibility assessment was supported by substantial evidence.	The ALJ ignored progressive nature of symptoms and periods of greater impairment.	Credibility supported by inconsistent activity and medical findings.	No; remand required for proper credibility analysis.
Whether the ALJ erred by focusing on daily activities to assess disability without accounting for their limited relevance to work capacity.	Daily activities do not equate to ability to perform substantial work.	Activities show some functional capacity.	No; remand necessary to evaluate activities appropriately.
Whether the ALJ considered the combined effects and progressive evolution of multiple impairments.	ALJ ignored the cumulative impact and progression of back disease and obesity.	ALJ considered individual impairments and overall record.	No; remand to assess combined effects.

Herron v. Shalala, 19 F.3d 329 (7th Cir. 1994) (requirement to articulate reasons for accepting or rejecting lines of evidence)
Whitney v. Schweiker, 695 F.2d 784 (7th Cir. 1982) (ALJ must weigh all evidence and not ignore contrary evidence)
Myles v. Astrue, 582 F.3d 672 (7th Cir. 2009) (treating-source evaluation requires addressing all parts of medical reports)
Clifford v. Apfel, 227 F.3d 863 (7th Cir. 2000) (daily activities alone do not prove lack of disabling pain)
Carradine v. Barnhart, 360 F.3d 751 (7th Cir. 2004) (walking or rehabilitative activities not necessarily transferable to work)
Schmidt v. Barnhart, 395 F.3d 737 (7th Cir. 2005) (reminding that substantial evidence requires integrated analysis)
Elder v. Astrue, 529 F.3d 408 (7th Cir. 2008) (regarding proper application of § 404.1527 factors)
Hofslien v. Barnhart, 439 F.3d 375 (7th Cir. 2006) (discussing treating-physician evaluation framework)
Vertigan v. Halter, 260 F.3d 1044 (9th Cir. 2001) (relevance of rehabilitative activities to work capacity)