Rance v. Commissioner of Social Security, 4:14-cv-00076

Plaintiff William Jackson Rance applied for Social Security disability benefits after a workplace accident (alleged onset April 10, 2009); prior work as a truck tire delivery driver.
ALJ found several severe impairments (right wrist/hip/pelvic fracture residuals, degenerative disc disease, obesity, depressive disorder, intermittent explosive disorder, personality disorder) but concluded Rance could perform unskilled sedentary work without public contact and denied benefits.
Rance requested review; Appeals Council denied review, making the ALJ decision final for judicial review under 42 U.S.C. § 405(g).
Rance challenged the hearing procedures, the ALJ’s treatment of his treating neurologist’s testimony, the weight given to a vocational specialist, and omission of a wrist brace limitation in the RFC.
The district court found the hearing adversarial (contrary to SSA’s nonadversarial guarantee) and that the ALJ’s discounting of the neurologist lacked a logical explanation given a missing MRI, and therefore remanded; the court upheld the ALJ’s treatment of the vocational specialist and the no-wrist-brace RFC finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Procedural fairness at hearing	ALJ allowed medical expert to cross-examine neurologist and there were off-record communications; hearing became adversarial	ALJ’s conduct did not violate HALLEX and Plaintiff was not prevented from questioning witnesses	Court: Hearing was pervasively argumentative and not nonadversarial as required; remand on this ground
Treatment of treating neurologist’s credibility	Neurologist’s testimony was credible; ALJ improperly discounted it	ALJ discounted testimony as inconsistent with medical record	Court: Discounting unsupported because neurologist relied on an MRI absent from the record; remand required
Weight given to vocational specialist (nonmedical source)	Vocational specialist’s opinion should have been credited	ALJ may give nonmedical source less weight when inconsistent with medical evidence	Court: ALJ reasonably discounted vocational specialist where it conflicted with medical evidence; no reversal
RFC omission of wrist brace restriction	RFC should have included wrist brace limitation	Record, including orthopedic expert, supported no brace restriction; ALJ reasonably found no brace needed	Court: Substantial evidence supports ALJ’s conclusion; no reversal

Thomas v. Colvin, 745 F.3d 802 (7th Cir. 2014) (ALJ must build an accurate and logical bridge from evidence to conclusion)
Briscoe ex rel. Taylor v. Barnhart, 425 F.3d 345 (7th Cir. 2005) (Court upholds decisions applying correct legal standard and supported by substantial evidence)
Kastner v. Astrue, 697 F.3d 642 (7th Cir. 2012) (describes five-step SSA disability evaluation)
Clifford v. Apfel, 227 F.3d 863 (7th Cir. 2000) (claimant bears burden until step five)
Murphy v. Colvin, 759 F.3d 811 (7th Cir. 2014) (ALJ credibility findings entitled to deference if adequately explained)
Moore v. Apfel, 216 F.3d 864 (9th Cir. 2000) (HALLEX treated as internal guidance without binding legal effect)
Newton v. Apfel, 209 F.3d 448 (5th Cir. 2000) (noncompliance with HALLEX can be reversible if prejudicial)
Cromer v. Apfel, 234 F.3d 1272 (7th Cir. 2000) (declined to resolve HALLEX’s legal force where outcome unaffected)