Knell v. Bisignano, 3:23-cv-50310

Chelsea K. applied for Social Security disability benefits, alleging disability starting May 1, 2021, based on mental health disorders.
Her application was denied initially and upon reconsideration. She requested and received a hearing before an ALJ, where she testified with representation.
The ALJ found Chelsea had several severe mental impairments but concluded she was not disabled under the Social Security Act after applying the five-step analysis.
The ALJ gave limited weight to the medical opinion of Nurse Olivia Winters, finding it unsupported and inconsistent with other medical evidence, particularly the opinion of primary care provider Nurse Tiffany Kuhlmeyer and other treatment notes.
Chelsea appealed to the Appeals Council, which denied review, making the ALJ’s decision final. She sought review in federal court, challenging the ALJ’s handling of Nurse Winters’s opinion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the ALJ properly explain why Nurse Winters’s medical opinion was not persuasive?	ALJ failed to adequately explain supportability/consistency and ignored evidence consistent with Winters’s opinion; "cherry-picked" evidence.	ALJ properly evaluated supportability and consistency; did not need to discuss every piece of evidence for each medical opinion; record as a whole supports finding.	ALJ minimally articulated reasons and decision is supported by substantial evidence; affirmed.

Moore v. Colvin, 743 F.3d 1118 (7th Cir. 2014) (substantial evidence standard; ALJs must provide a logical bridge between evidence and conclusions)
Burmester v. Berryhill, 920 F.3d 507 (7th Cir. 2019) (standard for reviewing ALJ’s credibility and factual findings)
Gedatus v. Saul, 994 F.3d 893 (7th Cir. 2021) (court will reverse ALJ only if record compels contrary result)
Curvin v. Colvin, 778 F.3d 645 (7th Cir. 2015) (ALJ’s credibility findings given deference; only disturbed if "patently wrong")