Michelle Baptist v. Kilolo Kijakazi, 74 F.4th 437

Michelle Baptist was in a 2013 car accident and thereafter reported neck/shoulder pain, hand numbness, reduced ROM, and headaches.
Imaging and testing showed mild multilevel cervical degenerative changes, small disc bulges, and only mild radiculopathy on EMG; treating physicians repeatedly recommended conservative treatment (medication, PT, occasional injections).
An intracranial aneurysm was identified in 2014; Baptist underwent clipping in January 2016, had postoperative infarcts but recovered with full strength, normal gait, and stable aneurysms on follow-up.
Baptist’s primary care physician, Dr. Ellison, completed disability forms asserting extreme limits (e.g., cannot stand/walk >2 hours), but also noted lack of objective findings and suspected exaggeration/malingering; a nurse practitioner (Wangard) provided conflicting functional opinions.
State agency non‑examining consultants (2015) found Baptist capable of a full range of light work (sit/stand/walk ~6 hours); the ALJ adopted a light‑work RFC, denied benefits, and the district court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ impermissibly “played doctor” by relying on 2015 non‑examining opinions despite later 2016–2018 medical records	Baptist: Later evidence (2016 clipping/infarcts; 2018 cervical MRI) could have changed consultants’ RFC and required updated medical review	Kijakazi: Later records showed no lasting worsening; treating physicians reviewed and recommended conservative care, so prior opinions were not outdated	Court: Held ALJ did not err; later records did not reasonably undercut 2015 consultants and treating docs showed recovery/stability
Whether ALJ improperly discounted treating providers’ opinions that claimant couldn’t stand/walk >2 hours	Baptist: ALJ should have given controlling weight to treating opinions indicating severe limitations	Kijakazi: Treating opinions were based on claimant’s subjective reports, conflicted with objective findings and conservative treatment, and included provider doubts about credibility	Court: Held ALJ permissibly gave little weight to those opinions for the stated reasons

Clifford v. Apfel, 227 F.3d 863 (7th Cir. 2000) (standard for reversing ALJ when legal error or lack of substantial evidence)
Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (definition of substantial evidence)
Karr v. Saul, 989 F.3d 508 (7th Cir. 2021) (substantial‑evidence review and deference to ALJ factfinding)
Moreno v. Berryhill, 882 F.3d 722 (7th Cir. 2018) (remand required where later records could reasonably change non‑examining opinion)
Stage v. Colvin, 812 F.3d 1121 (7th Cir. 2016) (remand where new imaging changed medical picture and non‑examining opinion was outdated)
Goins v. Colvin, 764 F.3d 677 (7th Cir. 2014) (ALJ may not interpret raw medical data without expert support)
Pavlicek v. Saul, 994 F.3d 777 (7th Cir. 2021) (ALJ may rely on older assessments when later testing, as interpreted by physicians, does not show worsening)
Bakke v. Kijakazi, 62 F.4th 1061 (7th Cir. 2023) (treating physicians’ mild reactions to new tests can justify reliance on prior consultants)
McHenry v. Berryhill, 911 F.3d 866 (7th Cir. 2018) (warning against ALJs interpreting complex medical imaging themselves)
Israel v. Colvin, 840 F.3d 432 (7th Cir. 2016) (even “mild” imaging changes can be decisive and may require further medical opinion)