Krystal Goins v. Carolyn Colvin
2014 U.S. App. LEXIS 16055
| 7th Cir. | 2014Background
- Plaintiff sought Supplemental Security Income and challenged the ALJ’s denial of benefits.
- 1998 MRI showed a herniated disc; medical record gaps exist until 2007 when pain treatment began.
- 2010 MRI revealed degenerative disc disease, stenosis, and a Chiari I malformation.
- ALJ relied on non-examining consulting physicians who did not review the 2010 MRI and were opaque about the evidence.
- ALJ found the plaintiff not credible and inadequately considered obesity and combined spinal issues.
- Court reverses and remands for a proper medical evaluation and consideration ofEvidence and credibility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly evaluated credibility | Shauger and related caselaw require credibility to be assessed in light of medical evidence. | ALJ properly weighed the testimony against the residual functional capacity. | Remanded for reevaluation of credibility with proper evidence. |
| Whether the MRI from 2010 should have been considered | The 2010 MRI shows serious conditions not reviewed by the ALJ. | ALJ relied on earlier records and did not need the 2010 MRI. | Remanded for medical evaluation incorporating 2010 MRI. |
| Whether obesity and combination of impairments were properly considered | ALJ failed to account for obesity and multiple spinal problems in combination. | Obesity alone is not disabling and not properly combined. | Remanded to assess combined effects on ability to work. |
| Whether reliance on non-examining physicians without reviewing MRI is proper | Consulting physicians lacked adequate basis and failed to review new MRI. | Non-examining opinions can support the assessment if properly reasoned. | Remanded for reevaluation with proper medical evidence. |
Key Cases Cited
- Shauger v. Astrue, 675 F.3d 690 (7th Cir. 2012) (work despite disability; credibility considerations)
- Barnett v. Barnhart, 381 F.3d 664 (7th Cir. 2004) (disability determination and credibility)
- Henderson v. Barnhart, 349 F.3d 434 (7th Cir. 2003) (credibility and SSA procedures)
- Kelley v. Callahan, 133 F.3d 583 (8th Cir. 1998) (credibility and residual functional capacity)
- Green v. Apfel, 204 F.3d 780 (7th Cir. 2000) (must consider new medical evidence)
- Blakes ex rel. Wolfe v. Barnhart, 331 F.3d 565 (7th Cir. 2003) (medical evidence and SSA evaluation limits)
- Rohan v. Chater, 98 F.3d 966 (7th Cir. 1996) (avoid improper medical speculation)
- Bjornson v. Astrue, 671 F.3d 640 (7th Cir. 2012) (reliance on boilerplate language and credibility)