Lafontaine v. Commissioner of Social Security, 1:18-cv-00358

Plaintiff Janet LaFontaine suffers from chronic musculoskeletal and mental impairments (spondylosis, osteoarthritis, fibromyalgia, Ehlers–Danlos, ADHD, anxiety, depression) and had foot surgery after a 2015 workplace injury.
Treated at a pain clinic; prescribed opioid medications (morphine twice daily and Percocet four times daily) for chronic pain.
At the hearing LaFontaine testified her medications sometimes cause “brain fog” and make her feel “sluggish”; treatment notes also recorded medication-related fatigue.
Agency consultants and the ALJ found an RFC for light work with some postural and mental limitations, but not limitations for sustained concentration; the ALJ concluded she could perform her past semi-skilled work as a grocery checker and denied benefits.
The ALJ’s written decision mentioned that medication “helped some” but did not acknowledge LaFontaine’s testimony about medication side effects.
The Appeals Council denied review; the district court reversed and remanded, holding the ALJ erred by failing to address medication side effects and their possible impact on RFC and ability to perform past work.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly considered medication side effects when evaluating symptom severity and RFC	LaFontaine testified opioids cause brain fog/sluggishness; ALJ ignored this evidence and failed to account for potential work-limiting side effects	Commissioner did not meaningfully respond to the side-effects issue; generally relied on medical opinions supporting the RFC	Court: ALJ erred by failing to acknowledge or discuss testimony about medication side effects; remand required
Whether the error was harmless	Error could lead to a more restrictive RFC that would preclude LaFontaine’s past semi-skilled work	No harmless-error argument presented	Court: Because the error could affect the RFC and step‑4 finding and defendant offered no harmlessness argument, remand was appropriate

Plessinger v. Berryhill, 900 F.3d 909 (7th Cir. 2018) (medication and side effects may inform symptom severity)
Flores v. Massanari, [citation="19 F. App'x 393"] (7th Cir. 2001) (medication side effects can create work limitations)
Baldwin v. Berryhill, [citation="746 F. App'x 580"] (7th Cir. 2018) (ALJ may not cherry-pick supporting evidence while ignoring contrary evidence)
Terry v. Astrue, 580 F.3d 471 (7th Cir. 2009) (ALJ must build a logical bridge from evidence to conclusions)
Lopez ex rel. Lopez v. Barnhart, 336 F.3d 535 (7th Cir. 2003) (court conducts critical review but does not reweigh evidence)
Richardson v. Perales, 402 U.S. 389 (1971) (definition of substantial evidence standard)
Schomas v. Colvin, 732 F.3d 702 (7th Cir. 2013) (ALJ decision is the Commissioner’s final decision when Appeals Council denies review)