Latesha Moon v. Carolyn Colvin
763 F.3d 718
| 7th Cir. | 2014Background
- Moon, age 26 at application, has long-term medical issues (notably severe obesity, back/joint problems, sleep apnea, depression) and documented migraines starting in 2005.
- She applied for Social Security disability; an ALJ denied benefits after a 2010 hearing, finding she could perform a limited range of sedentary work with a sit/stand option.
- The ALJ found headaches part of a severe combination of impairments at step two but gave little weight to migraine limitations in the residual functional capacity (RFC) assessment.
- The ALJ relied primarily on two nonexamining reviewers (Dr. Kim and Dr. Francis) and cited an unremarkable 2008 brain MRI and alleged inconsistencies in Moon’s testimony to discount the migraine evidence.
- Moon testified her migraines worsened by 2010, occurring on most days and sometimes requiring up to three days in bed; she reported medication side effects but medical records did not document those side effects.
- The Appeals Council and district court affirmed; the Seventh Circuit reversed, finding the ALJ failed to build a logical bridge regarding the migraine evidence and remanded for further proceedings covering the period after August 2008.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ properly evaluated migraine evidence in RFC | Moon: ALJ ignored/discounted extensive treatment history and her testimony about frequent, disabling migraines | Gov: Nonexamining doctors accounted for migraines; ALJ permissibly weighed inconsistencies and lack of documentation | Reversed: ALJ failed to build a logical bridge; migraine evidence not adequately addressed |
| Whether ALJ properly relied on unremarkable MRI to downplay migraines | Moon: MRI does not undermine migraine diagnosis; MRIs rule out other causes but are consistent with migraines | Gov: MRI supports ALJ's skepticism of severity | Reversed: ALJ misread MRI significance and impermissibly played doctor |
| Whether ALJ permissibly discounted Moon’s testimony about symptoms/side effects | Moon: ALJ did not adequately explain credibility findings and mischaracterized records (e.g., denying headaches) | Gov: Lack of medical documentation supports discounting testimony | Reversed: Credibility doubts not supported; ALJ mischaracterized record and failed to explain rejection of testimony |
| Whether nonexamining doctors’ opinions cure ALJ’s analytic gaps (Chenery issue) | Moon: ALJ must itself relate migraine evidence to RFC; agency cannot rely on post-hoc justification | Gov: Drs. Kim and Francis implicitly considered migraines, so ALJ need not do more | Reversed: Court refuses post-hoc defenses; nonexamining opinions did not supply a logical bridge |
Key Cases Cited
- Moore v. Colvin, 743 F.3d 1118 (7th Cir.) (standard of review and requirement that ALJ build a logical bridge)
- Richardson v. Perales, 402 U.S. 389 (Supreme Court) (definition of substantial evidence review)
- Blakes ex rel. Wolfe v. Barnhart, 331 F.3d 565 (7th Cir.) (warning against ALJs "playing doctor")
- Rohan v. Chater, 98 F.3d 966 (7th Cir.) (ALJs must not make independent medical findings)
- SEC v. Chenery Corp., 318 U.S. 80 (Supreme Court) (agency cannot defend decision on grounds it did not invoke)
- Kastner v. Astrue, 697 F.3d 642 (7th Cir.) (applying Chenery to Social Security proceedings)