MITCHELL v. COLVIN, 1:14-cv-01112

Background

Plaintiff Prudence Anessa Mitchell applied for Social Security Disability Insurance (DIB) with an alleged onset date of September 10, 2010; the ALJ denied benefits and the Appeals Council affirmed, making the ALJ decision final.
Ms. Mitchell alleges primarily chronic back problems from a work injury (thoracic/lumbar degenerative disc disease, disc protrusion at T11–T12) and related limitations; providers recommended physical therapy and one treating physician noted lifelong positional limits.
Additional alleged impairments include carpal tunnel syndrome, obesity, neuropathy, and mental conditions (depression, anxiety, ADD, PTSD); consultative exams showed largely normal motor/sensory findings and intact grip/fine motor skills.
Treating physician Dr. Bobzien signed a 2012 statement declaring Mitchell disabled; his clinical findings relied substantially on a nurse practitioner’s reports rather than independent objective testing.
The ALJ found Mitchell insured through Dec. 31, 2015; severe impairments were thoracic degenerative disc disease and obesity; RFC—light work with limitations; concluded she could perform past relevant work (real estate agent and gift wrapper) and was not disabled.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ failed to address carpal tunnel syndrome severity	Mitchell: ALJ ignored/failed to label severity of carpal tunnel and explain rationale	Commissioner: ALJ discussed EMG, normal exam findings, and consultative exam showing normal grip/fine motor skills, supporting non-severe finding	Court: ALJ adequately considered carpal tunnel and rationale supports non-severe conclusion
Whether ALJ improperly failed to give controlling weight to treating physician Dr. Bobzien	Mitchell: Dr. Bobzien treated her >2 years and opined she is disabled; ALJ should have given controlling weight	Commissioner: Opinion that claimant is "disabled" is an administrative determination reserved to SSA; Bobzien’s opinion lacked objective support and relied on NP findings	Court: ALJ properly declined controlling weight; treating statement was conclusory/unsupported and not entitled to special weight
Whether ALJ failed to consider severity of mental impairments (depression, anxiety, ADD, PTSD)	Mitchell: ALJ erred in finding mental impairments non-severe and in rejecting PTSD/ADD as medically determinable	Commissioner: Consultative, treating, and state-reviewer evidence showed only mild limitations; no extended decompensation; some exams within normal limits	Court: ALJ reasonably evaluated paragraph B areas, found only mild limitations, and permissibly concluded mental impairments were non-severe or not medically determinable
Whether ALJ’s RFC and step-four finding are supported by substantial evidence	Mitchell: RFC and step-four finding inconsistent with her reported limitations and treating opinions	Commissioner: RFC based on medical records, consultative exams, and reviewer opinions; RFC permits past relevant jobs	Court: Substantial evidence supports RFC and finding that Mitchell can perform past relevant work; decision affirmed

Key Cases Cited

Craft v. Astrue, 539 F.3d 668 (7th Cir. 2008) (RFC is claimant's maximum capacity despite limitations)
Dixon v. Massanari, 270 F.3d 1171 (7th Cir. 2001) (definition of substantial evidence)
Overman v. Astrue, 546 F.3d 456 (7th Cir. 2008) (court may not reweigh evidence)
Parker v. Astrue, 597 F.3d 920 (7th Cir. 2010) (ALJ must build an "accurate and logical bridge" to conclusions)
Carlson v. Shalala, 999 F.2d 180 (7th Cir. 1993) (ALJ need not discuss every piece of evidence)
Herron v. Shalala, 19 F.3d 329 (7th Cir. 1994) (ALJ must consider all relevant evidence)
Scheck v. Barnhart, 357 F.3d 697 (7th Cir. 2004) (ALJ must articulate minimal, legitimate justification for weighing evidence)
Gudgel v. Barnhart, 345 F.3d 467 (7th Cir. 2003) (treating physician entitled to controlling weight if supported by objective evidence)
Skarbek v. Barnhart, 390 F.3d 500 (7th Cir. 2004) (treating-source opinion standards)
Bowen v. Yuckert, 482 U.S. 137 (1987) (definition of basic work activities and severity threshold)
Young v. Barnhart, 362 F.3d 995 (7th Cir. 2004) (requirement to provide "accurate and logical bridge")