L.D.R. by WAGNER v. Berryhill
920 F.3d 1146
| 7th Cir. | 2019Background
- Child (L.D.R.), born 2008, had chronic medical issues (asthma, recurrent middle-ear infections/hearing problems, sleep apnea, behavioral/attention problems) with varying severity from infancy through second grade.
- Mother filed multiple SSI applications (first when child was ~1); ALJ initially denied benefits, district court remanded for inadequate explanation; consolidated applications were reconsidered by a new ALJ.
- ALJ issued a detailed 28-page decision evaluating the child under the six regulatory functional-equivalence domains across applicable age ranges and found limitations "less than marked" until August 1, 2015, when marked limitations arose (interacting with others; caring for self) — disability onset set at Aug. 1, 2015 (just before second grade).
- District court affirmed the ALJ, and mother appealed both the timing of onset/analysis and constitutionality of rules barring retroactive benefits before application.
- Seventh Circuit reviewed de novo legal issues and for substantial evidence the ALJ’s factual findings, affirmed the ALJ and district court: substantial evidence supported the onset date and domain analyses, and rational-basis review upheld the ban on retroactive payments.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ sufficiently evaluated the six functional domains across applicable age categories | Mother: ALJ failed to make separate domain findings for each age gradation; needed more granular findings for meaningful review | ALJ considered relevant evidence across all age ranges and described typical functioning by age; separate segmented findings not required | Court: No error; regulations do not require separate findings for each age category; substantial evidence supports ALJ’s domain analysis |
| Whether medical evidence (ear infections, asthma, sleep apnea, behavioral meds) was properly weighed | Mother: ALJ minimized impairments and their impact; mischaracterized treatment effects and functional limitations | ALJ thoroughly considered medical records, treatment responses, school records, and improvements after interventions | Court: ALJ’s treatment of medical evidence was comprehensive and supported by record; not an invitation to reweigh evidence |
| Proper disability onset date (whether child disabled before Aug. 1, 2015) | Mother: Child was disabled earlier and entitled to earlier onset/benefits | ALJ: Evidence shows marked worsening beginning Aug. 1, 2015; earlier limitations were less than marked | Court: Substantial evidence supports Aug. 1, 2015 onset; affirmed |
| Constitutionality of rule barring retroactive SSI benefits before application | Mother: Rule violates equal protection (Fifth Amendment) by denying benefits to eligible children for months before application, punishing parental delay/poverty | Government: Rule serves rational bases — administrability, proof difficulties, incentivizing timely application to meet immediate needs | Court: Rational-basis review satisfied; statute/regulation constitutional |
Key Cases Cited
- Skinner v. Astrue, 478 F.3d 836 (7th Cir. 2007) (standard of review for ALJ decisions in social security appeals)
- Summers v. Berryhill, 864 F.3d 523 (7th Cir. 2017) (articulating deference and prohibition on reweighing evidence)
- San Antonio Indep. Sch. Dist. v. Rodriguez, 411 U.S. 1 (1973) (applying rational-basis scrutiny to wealth-based classifications)