Scott v. Astrue
647 F.3d 734
| 7th Cir. | 2011Background
- Shirley Scott applied for disability insurance benefits and supplemental security income alleging bipolar disorder and physical impairments.
- The SSA denied the claim; a magistrate judge upheld the denial after consent, leading to appellate review.
- Dr. Christine Tate, a psychiatrist, diagnosed bipolar disorder and evaluated Scott’s work-limiting abilities.
- Dr. Ellen Rozenfeld, a psychologist, opined milder limitations and questioned bipolar diagnosis; the ALJ credited Rozenfeld over Tate.
- A vocational expert testified on light-work options with certain postural and concentration requirements, influencing the RFC.
- The Seventh Circuit vacated and remanded for additional proceedings due to flaws in the ALJ’s treatment of medical opinions and credibility.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Credit given to treating psychiatrist | Scott (via Tate) should have controlling weight. | Rozenfeld’s opinions are consistent with record; Tate discounts. | Remand; ALJ erred in discounting Tate. |
| ALJ credibility assessment | ALJ improperly distrusts Scott’s testimony. | Credibility supported by objective findings. | Remand; credibility analysis flawed. |
| Residual functional capacity (RFC) for physical impairments | ALJ relied on insufficient evidence to limit lifting/carrying and standing. | Examination supports RFC. | Remand; need clear logical bridge between evidence and RFC. |
| Support for lifting and standing assumptions | Evidence of tremors and cane use entitle greater restrictions than found. | Record not showing greater limitations. | Remand; clarify physical capability findings. |
| Remand necessity | Case should be returned for further evaluation consistent with Tate’s findings. | Record indicates some limitations, but unresolved. | Remand with instructions for further proceedings. |
Key Cases Cited
- Punzio v. Astrue, 630 F.3d 704 (7th Cir. 2011) (treating-opinion weight and consistency with record)
- Campbell v. Astrue, 627 F.3d 299 (7th Cir. 2010) (proper evaluation of treating-source opinions)
- Moss v. Astrue, 555 F.3d 556 (7th Cir. 2009) (factors for discounting treating opinions)
- Denton v. Astrue, 596 F.3d 419 (7th Cir. 2010) (avoid cherry-picking medical evidence)
- Larson v. Astrue, 615 F.3d 744 (7th Cir. 2010) (mental illness requires understanding fluctuations)
- Myles v. Astrue, 582 F.3d 672 (7th Cir. 2009) (limitations may vary over time with treatment)
- Briscoe ex rel. Taylor v. Barnhart, 425 F.3d 345 (7th Cir. 2005) (need for logical bridge between evidence and conclusions)
- Barrett v. Barnhart, 355 F.3d 1065 (7th Cir. 2004) (requirement to articulate basis for physical-capability findings)