Martinez v. Astrue
630 F.3d 693
| 7th Cir. | 2011Background
- Three consolidated challenges to SSA denial of disability/SSI benefits were decided together.
- The court had previously criticized SSA ALJs in Spiva and Parker for credibility, mental-illness knowledge, and reliance on non-ALI evidence.
- Martinez, Rider, and Pound each alleged disability from physical and/or mental impairments with varying degrees of severity and functional impact.
- Martinez suffers severe depression and inflammatory polyarthritis, with significant hand impairment and daily suicidal ideation, largely dependent on family support.
- Rider alleges knee, back pain, obesity (BMI about 40) and driving impairment from that combination.
- Pound has multiple cardiovascular, neurological, and other symptoms with a limited post-2003 work history and uncertain treatment adequacy.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did ALJ improperly discount Martinez's credibility and pain claims? | Martinez's pain and fatigue are not adequately explained by objective findings; credibility not properly assessed. | ALJ reasonably found inconsistencies and relied on medical history; does not need to credit all symptom testimony. | Reversed for Martinez; remanded for proper credibility evaluation and integration of impairments. |
| Did ALJ err by underweighting treating-source opinions and ignoring aggregate impairment for Rider? | Treating physicians' opinions should control; obesity significantly worsens knee issue; aggregate effects must be considered. | Other physicians' non-treating opinions can be given more weight; knee condition evaluated without need for knee replacement. | Reversed for Rider; remanded to assess obesity's impact and aggregate disability. |
| Did ALJ improperly fail to evaluate Pound’s combined impairments and misread functional limits? | ALJ did not adequately assess the aggregate effect of Pound's cardiovascular, neurological, and other symptoms. | Evidence supports sedentary limitation based on the record; no single impairment dictates the outcome. | Affirmed Pound; not reversible as to Pound. |
Key Cases Cited
- Spiva v. Astrue, 628 F.3d 346 (7th Cir.2010) (criticized ALJ credibility assessments and medical evidence reliance)
- Parker v. Astrue, 597 F.3d 920 (7th Cir.2010) (addressed deficiencies in disability determinations)
- Lopez v. Barnhart, 336 F.3d 535 (7th Cir.2003) (credibility and evaluation of pain in disability claims)
- Campbell v. Astrue, 627 F.3d 299 (7th Cir.2010) (good reasons required for discounting treating sources)
- Johnson v. Barnhart, 449 F.3d 804 (7th Cir.2006) (pain etiology not directly inferred from medical reports)
- Gentle v. Barnhart, 430 F.3d 865 (7th Cir.2005) (consideration of subjective complaints in disability analysis)
- Golembiewski v. Barnhart, 322 F.3d 912 (7th Cir.2003) (interaction of impairments relevant to disability determination)
- Villano v. Astrue, 556 F.3d 558 (7th Cir.2009) (aggregate impairments and functional limitations)