Meretha Arnold v. Andrew Saul
990 F.3d 1046
7th Cir.2021Background
- Meretha Arnold applied for Social Security disability benefits, alleging disabling back, heart, joint problems, and chronic pain syndrome.
- After initial denial, Arnold testified at an ALJ hearing; a vocational expert also testified.
- The ALJ found several severe impairments but concluded Arnold retained sufficient RFC to perform her past work as a daycare center director and therefore was not disabled.
- The ALJ relied in part on records noting Arnold reported medications were effective "without any side effects." The ALJ did not otherwise analyze medication side effects in detail.
- The record contains some references to possible side effects (a physician’s warning against working/driving/operating machinery while medicated; complaints of fatigue, mouth sores, nightmares, sleep problems, and occasional dizziness), but no evidence linking those effects to work limitations.
- The district court affirmed; the Seventh Circuit affirmed, holding that any findings about side effects would be speculative because there was no evidence they actually limited Arnold’s ability to work.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ failed to evaluate medication side effects in determining disability | Arnold: ALJ ignored evidence that medications caused side effects that impaired her ability to work | Commissioner: Record lacks evidence that side effects were experienced in a way that limited work; ALJ noted statements that medications had no side effects | Affirmed: No requirement to make specific findings because record contains no evidence that side effects actually affected work capacity; any such finding would be speculative |
Key Cases Cited
- Stephens v. Berryhill, 888 F.3d 323 (7th Cir. 2018) (standard of review: de novo for district court and substantial-evidence review of ALJ findings)
- Zoch v. Saul, 981 F.3d 597 (7th Cir. 2020) (definition of substantial evidence)
- Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (definition and explanation of substantial-evidence standard)
- Schaaf v. Astrue, 602 F.3d 869 (7th Cir. 2010) (ALJ need not assume claimant suffers all possible side effects absent evidence)
- Nelson v. Sec'y of Health & Human Servs., 770 F.2d 682 (7th Cir. 1985) (ALJ not required to speculate about impairments not supported by the record)