Smith v. Astrue, 1:11-cv-03113

Plaintiff Robert Smith filed for Title XVI SSI on May 8, 2007, which was denied then reconsidered.
An Administrative Law Judge denied benefits on January 27, 2009, and the Appeals Council denied review on March 9, 2010.
The case was brought under 42 U.S.C. § 405(g) and plaintiff seeks judicial review in the district court.
Plaintiff alleges schizophrenia and related symptoms impacting work ability; medical records include Lawrence Correctional Center material and consultative and psychiatric reviews.
The ALJ concluded plaintiff could perform unskilled medium work and found no disability, but the court remands for further consideration of evidence and RFC narrative.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ adequately assessed credibility	Smith lacked a clear credibility determination by the ALJ.	The ALJ implicitly evaluated credibility using evidence in record.	Remand for explicit credibility analysis and explicit weighing of evidence.
Whether the ALJ properly considered Lawrence Correctional Center records	These records contain extensive mental-health symptoms the ALJ ignored.	Records do not alter the overall RFC and may be disruptive to conclusions.	Remand for thorough consideration of all medical evidence, including Lawrence records.
Whether the RFC lacked a narrative tying the evidence to conclusions	Rozenfeld’s B criteria findings and Langgut’s findings were not adequately integrated into the RFC.	Rozenfeld’s opinion supports a modest RFC; the ALJ adopted it for the RFC.	Remand to provide a detailed narrative linking evidence to RFC.
Whether the record was adequately developed and weight given to opinions	ALJ failed to discuss all medical evidence and did not explain weight given to Dr. Langgut.	ALJ has discretion in weighing evidence and completing the record.	Remand to develop the record and provide a rational bridge between evidence and conclusions.

Clifford v. Apfel, 227 F.3d 863 (7th Cir. 2000) (requires logical bridge from evidence to denial and meaningful appellate review)
Zurawski v. Halter, 245 F.3d 881 (7th Cir. 2001) (limits on credibility analysis guidance and need for specific reasoning)
Getch v. Astrue, 539 F.3d 473 (7th Cir. 2008) (ALJ must articulate reasons for accepting or rejecting evidence)
Nelms v. Astrue, 553 F.3d 1098 (7th Cir. 2009) (duty to develop the record when claimant appears without counsel)
Myles v. Astrue, 582 F.3d 672 (7th Cir. 2009) (remand when a logical bridge between evidence and conclusions is missing)
Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (substantial evidence standard and factual review)