Laggner v. Commissioner of Social Security, 1:14-cv-00272

Background

Plaintiff Alena L. Laggner applied for Supplemental Security Income (SSI) on December 12, 2011; claim denied by ALJ May 14, 2013 and Appeals Council; district court review followed.
Medical history: multiple lumbar and cervical discectomies/fusion (2008–2011), recurrent back/neck pain with radicular symptoms, and psychiatric diagnoses including major depressive disorder, panic disorder, and generalized anxiety.
Treatment record shows episodic ER visits, intermittent pain-management care, gaps in mental-health specialty treatment (often due to loss of insurance/financial limits), and only limited objective findings on many exams.
ALJ found severe impairments (degenerative disc disease, prior spine surgeries, depression, anxiety) but assigned an RFC for light work with non-physical limits: simple, routine, repetitive tasks; no fast-paced production; few workplace changes; superficial interaction with others.
VE testimony supported availability of a significant number of light (and alternatively sedentary) jobs; ALJ concluded Laggner not disabled as of the December 12, 2011 application date.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ improperly discounted plaintiff’s symptom testimony/credibility	Laggner says ALJ erred by discounting her pain and mental-health complaints and failed to account for her lack of treatment due to loss of insurance	ALJ relied on objective findings, inconsistent statements, limited/episodic treatment, OTC medication use, and absence of treating opinion showing greater limits	Court: ALJ’s credibility finding supported by record and not "patently wrong"; affirmed
Whether ALJ’s mental RFC fails to account for diagnosed mental impairments	Laggner argues RFC insufficient for panic/agoraphobia, isolation, poor concentration and energy	ALJ relied on state agency psychologists and overall record; RFC is reserved to the Commissioner and is supported by reviewers	Court: RFC adequately accounts for mental limits; affirmed
Whether ALJ constructively reopened prior DIB/SSI applications	Laggner contends ALJ effectively reconsidered prior denials by discussing pre-2011 evidence	Commissioner/ALJ state she considered the full medical history only to assess the 2011 application and explicitly declined to reopen prior claims	Court: No constructive reopening; ALJ clearly limited decision to post-December 12, 2011; affirmed
Whether substantial evidence supports denial at step five	Laggner implies combined limitations preclude competitive work	Commissioner points to VE testimony and RFC yielding available jobs in economy even if reduced to sedentary level	Court: Substantial evidence supports step-five finding; affirmed

Key Cases Cited

Schmidt v. Barnhart, 395 F.3d 737 (7th Cir. 2005) (standard of substantial-evidence review)
Clifford v. Apfel, 227 F.3d 863 (7th Cir. 2000) (ALJ findings upheld unless not supported by substantial evidence or wrong legal standard)
Shideler v. Astrue, 888 F.3d 306 (7th Cir. 2018) (ALJ credibility determinations entitled to special deference)
Berger v. Astrue, 516 F.3d 539 (7th Cir. 2008) (credibility findings stand if some support in record)
Simila v. Astrue, 573 F.3d 503 (7th Cir. 2009) (ALJ need not be flawless; credibility assessment may be upheld despite imperfections)