Seigfreid v. Saul, 2:20-cv-00136

Background

Claimant Brian Seigfreid applied for DIB, alleging disability beginning June 12, 2015; insured through December 31, 2015 (period at issue ≈ 6 months).
ALJ denied benefits after hearing, finding severe impairments including lumbar/cervical degenerative disc disease, fibromyalgia, hip disorder, recurrent pancreatitis, migraines, depression, and anxiety.
ALJ assessed an RFC for sedentary work with multiple physical and mental restrictions (no ladders, occasional stoop/kneel/overhead reach, simple routine tasks, 2-hour concentration periods, no public interaction, limited coworker/supervisor contact).
ALJ found claimant unable to perform past relevant work but could perform several jobs existing in significant numbers nationally; Appeals Council denied review.
District court affirmed most RFC reasoning but found error in the ALJ’s treatment of two treating mental‑health source opinions (psychiatrist Dr. Egbert Tan and therapist Jody Ossi), concluding the ALJ failed to adequately weigh/take into account treating relationship, specialty, treatment notes, and temporal applicability of their opinions.
Court vacated and remanded for further consideration of the treating mental‑health opinions; other challenges (consultative exam, post‑insured hip surgery, symptom/activity assessment) were rejected.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
RFC / medical‑opinion weighting for physical limitations	ALJ improperly discounted most medical opinions and impermissibly “played doctor” by assigning sedentary RFC contrary to consultative PE	ALJ permissibly discounted opinions formed without full record and reasonably relied on consultative exam and other evidence	ALJ’s physical‑RFC reasoning was supported by substantial evidence; no reversible error on physical‑opinion weighting
Post‑insured hip surgery	ALJ ignored or gave only cursory consideration to hip surgery performed ~2 years after date last insured, which allegedly shows greater severity during insured period	Subsequent surgery does not necessarily reflect condition during insured period; ALJ discussed surgery and relied on contemporaneous imaging showing less severe problems during insured period	No error; brief discussion of post‑date surgery was adequate and ALJ reasonably concluded condition worsened after insured period
Symptom evaluation / activities	ALJ improperly relied on claimant’s May 2015 strenuous activities (moving boxes, painting, fishing) without acknowledging ensuing ER visit for severe pain	ALJ acknowledged ER visit; the fact claimant undertook strenuous activities is probative of functional ability even if those activities triggered isolated pain episodes	ALJ’s symptom assessment was reasonable; activities were a permissible part of credibility evaluation and were not treated as evidence of sustained full‑time capability
Weight to treating mental‑health opinions (Dr. Tan & J. Ossi)	ALJ erred in giving their Mental Medical Source Statements little weight (reasons: late dated, possibly drafted by therapist, inconsistent with GAFs)	ALJ argued opinions were post‑date, possibly merely signed by physician, inconsistent with GAF scores, and not supported by intensive treatment/hospitalization	Remand required: ALJ’s stated reasons were inadequate in aggregate—he failed to address treating relationship length/frequency, specialty, consistency with treatment notes, and ambiguity about period addressed; discounting as given was not sufficiently explained

Key Cases Cited

L.D.R. by Wagner v. Berryhill, 920 F.3d 1146 (7th Cir. 2019) (standard of review: uphold ALJ if correct legal standards and substantial evidence support decision)
Jelinek v. Astrue, 662 F.3d 805 (7th Cir. 2011) (administrative‑review standards)
Schmidt v. Astrue, 496 F.3d 833 (7th Cir. 2007) (ALJ may discount medical opinions and RFC need not mirror any single opinion)
Diaz v. Chater, 55 F.3d 300 (7th Cir. 1995) (ALJ resolves evidentiary conflicts)
Israel v. Colvin, 840 F.3d 432 (7th Cir. 2016) (treating physician opinion controlling if well supported and not inconsistent with other evidence)
Gudgel v. Barnhart, 345 F.3d 467 (7th Cir. 2003) (treating‑physician weight framework)
Stepp v. Colvin, 795 F.3d 711 (7th Cir. 2015) (courts will uphold all but the most patently erroneous reasons for discounting treating assessments)
Collins v. Berryhill, [citation="743 F. App'x 21"] (7th Cir. 2018) (ALJ need only minimally articulate reasons for the weight given a treating source)
Vang v. Saul, [citation="805 F. App'x 398"] (7th Cir. 2020) (factors to consider when not giving treating opinion controlling weight)
Hall v. Berryhill, 906 F.3d 640 (7th Cir. 2018) (application of 20 C.F.R. § 404.1527(c) factors)
Denton v. Astrue, 596 F.3d 419 (7th Cir. 2010) (GAF scores are not determinative of functional capacity)