512 F. App'x 603
7th Cir.2013Background
- Sawyer challenged denial of Social Security disability benefits; ALJ denied and district court upheld; she appeals.
- Sawyer, age 31, suffered an electrical shock at work; initial ER exam found no permanent injury and normal speech and movement.
- Over 2007–2008 Sawyer reported fatigue, anxiety, insomnia, panic, and varying psychiatric symptoms; multiple clinicians issued mixed assessments.
- Treating and consulting physicians proposed PTSD, anxiety, adjustment disorder, or conversion symptoms; some noted possible malingering or inconsistent reporting.
- Hearing in August 2009 included two doctors, a vocational expert, and Sawyer; VE testified she could work in unskilled jobs but not past work.
- ALJ found Sawyer not disabled, concluded she could perform unskilled work, Appeals Council denied review; standard of review for substantial evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credibility assessment | Sawyer's credibility not properly evaluated per SSR 96-7p. | ALJ credited medical evidence and found inconsistencies undermining credibility. | ALJ's credibility finding upholding substantial evidence. |
| Weight of medical opinions | ALJ ignored treating sources (Mclnerney, Alfrod) as medical opinions on disability. | ALJ appropriately summarized opinions; some remarks not medical opinions; weighed experts under regulations. | ALJ properly weighed medical opinions under 20 C.F.R. § 404.1527. |
| State agency opinions and residual functional capacity | State psychologist Appleton’s opinions about detailed instructions undermine RFC. | Appleton’s opinions were incorporated into the narrative RFC; not binding as disability determination. | RFC supported by integrated medical evidence including state agency input. |
| Conflict between VE testimony and DOT | ALJ should have asked VE about conflicts with the Dictionary of Occupational Titles. | No actual conflict identified; inquiry optional if no conflict exists. | No reversible error; no actual DOT-VE conflict found. |
Key Cases Cited
- Craft v. Astrue, 539 F.3d 668 (7th Cir. 2008) (credibility and medical evidence bridge required)
- Villano v. Astrue, 556 F.3d 558 (7th Cir. 2009) (credibility not dismissed solely for lack of objective evidence)
- Schaaf v. Astrue, 602 F.3d 869 (7th Cir. 2010) (deference to ALJ credibility findings)
- Overman v. Astrue, 546 F.3d 456 (7th Cir. 2008) (ALJ must identify and resolve conflicts between VE and DOT)
- Roberson v. Astrue, 481 F.3d 1020 (8th Cir. 2007) (mild-to-moderate limitations may still allow satisfactory functioning)