Trisha Reynolds v. Kilolo Kijakazi
25 F.4th 470
7th Cir.2022Background
- Claimant Trisha Reynolds (born 1992) applied for Social Security disability benefits alleging migraines, vertigo, and major depressive disorder with anxious distress, and amended her onset date to the application date (Sept. 25, 2017).
- Administrative proceedings: initial denials, ALJ hearing, ALJ found severe impairments (migraines, depression) but determined claimant not disabled; Appeals Council denied review; district court affirmed.
- ALJ RFC: full range of work with non-exertional limits — never climb ladders/ropes/scaffolds; avoid moving machinery, heights, extreme heat; moderate noise; work learnable in 30 days or less; simple routine tasks; routine changes; occasional interaction with coworkers and supervisors; no interaction with the general public; capable of remaining on task in two-hour increments.
- ALJ credited the opinion of state psychologist B. Randal Horton, Psy.D. (unskilled work; brief supervision and interactions with coworkers) and found Dr. Predina’s opinion that claimant would "likely struggle" with coworkers speculative and unpersuasive.
- Central dispute: whether the ALJ erred by omitting a qualitative ("superficial" or limited-quality) interaction restriction in the RFC despite medical notes showing intermittent anger, difficulty regulating emotions, and some clinician observations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ erred by failing to include a qualitative ("superficial") limitation on interactions with supervisors/coworkers in the RFC | Reynolds: medical records and clinician notes show she "struggles" with emotional regulation and interacting, and DOT/definitions support a more restrictive interpretation of "occasional" interactions | Commissioner/ALJ: no medical opinion prescribed a qualitative interaction limit; ALJ relied on Dr. Horton and claimant testimony; "occasional" interactions and no public contact accommodate anxiety | Court affirmed: no medical evidence required such a qualitative limit; ALJ not required to invent or infer limitations; substantial evidence supports RFC |
Key Cases Cited
- Arnold v. Saul, 990 F.3d 1046 (7th Cir. 2021) (standard of review: substantial-evidence inquiry)
- Gedatus v. Saul, 994 F.3d 893 (7th Cir. 2021) (courts may not reweigh evidence; ALJ must provide logical bridge from evidence to conclusion)
- Deborah M. v. Saul, 994 F.3d 785 (7th Cir. 2021) (ALJ must include limitations supported by the medical record)
- Yurt v. Colvin, 758 F.3d 850 (7th Cir. 2014) (ALJ must include only medically supported limitations in RFC)
- Rice v. Barnhart, 384 F.3d 363 (7th Cir. 2004) (ALJ not required to adopt limitations not supported by any treating or examining source)