Reed v. Colvin, 656 F. App'x 781

Polly Reed (age 50 at application) injured her left leg in a June 2010 motorcycle accident: skin loss, large cut around left knee, fractures of tibia and fibula treated with intramedullary rod and screws and skin grafts.
Post-accident treatment: physical therapy, pain medication (Norco), orthopedist (Dr. Wright) cleared her to return to work with regular duties by November 2010; X-rays showed fractures healing and hardware well positioned.
Reed reported ongoing pain, intermittent swelling, limp, and use of a cane at times; consulting podiatrist and later spine/neck complaints arose in 2011–2012 (cervical stenosis diagnosed in 2012).
State-agency reviewers (2011) assessed RFC consistent with light work with some postural restrictions; vocational expert testified Reed could perform some past work (as performed) or other light unskilled jobs with sit/stand option.
ALJ found severe impairment (left leg), non-severe neck/shoulder issues, discounted Reed’s subjective limitations as not fully credible, concluded she retained RFC for light work with restrictions, denied benefits; Appeals Council and district court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ failed to account for neck/right-shoulder limitations in RFC	Reed: ALJ should have included reaching/other limits from neck/shoulder pain	ALJ considered records and limited lifting/carrying but reasonably found limits did not preclude light work	Court: ALJ adequately considered and tied records to RFC; no error
Whether ALJ improperly relied on activities of daily living	Reed: ALJ overemphasized chores and drew impermissible inference of ability to work	ALJ used activities as one factor and noted breaks and limitations	Court: No improper inference; ALJ did not equate ADLs with ability to work
Whether ALJ erred in adverse credibility finding	Reed: ALJ ignored consistent work history and evidence of ongoing pain/cane use	ALJ cited inconsistencies with medical observations (normal gait, clearance to work) and state opinions	Court: Credibility determination supported by record and not patently wrong
Whether Reed was entitled to a closed period of disability (>=12 months) post-accident	Reed: Even if not currently disabled, she was disabled for at least 12 months after accident	ALJ emphasized evidence showing healing and functional recovery well before one year (Dr. Wright’s 5-month clearance, normal exams)	Court: ALJ’s discussion made clear Reed did not establish a 12-month disabling period; affirmed

Stark v. Colvin, 813 F.3d 684 (7th Cir. 2016) (ALJ should not equate daily activities with capacity for full-time work)
Moore v. Colvin, 743 F.3d 1118 (7th Cir. 2014) (cautions against overreliance on ADLs for disability determinations)
Roddy v. Astrue, 705 F.3d 631 (7th Cir. 2013) (same; scrutiny of ALJ inferences from ADLs)
Loveless v. Colvin, 810 F.3d 502 (7th Cir. 2016) (work history is a factor but not dispositive in credibility assessments)
Hill v. Colvin, 807 F.3d 862 (7th Cir. 2015) (work history should be considered favorably but is not controlling)
Curvin v. Colvin, 778 F.3d 645 (7th Cir. 2015) (credibility findings must be tied to record evidence)
Pepper v. Colvin, 712 F.3d 351 (7th Cir. 2013) (same; standard for reviewing credibility assessments)