Walker v. Berryhill, 900 F.3d 479

Sean Walker suffered a stroke in January 2008 and was unable to return to work; medical records show progressive cognitive and physical decline through 2014.
Walker applied for disability insurance (Title II) and supplemental security income (Title XVI), claiming onset January 15, 2008; later filed a separate SSI claim alleging disability as of December 5, 2014, which the agency granted.
A later ALJ, while accepting the agency's finding that Walker was disabled as of December 5, 2014, concluded Walker was not disabled at any time from January 2008 to December 2014 and assigned an RFC allowing certain sedentary work.
The ALJ gave significant weight to a one-time April 2012 psychologist assessment (Dr. Roy) and only partial weight to the treating physician Dr. Goudy’s August 2012 opinion that Walker had worsening dizziness, balance problems, short-term memory deficits, and could not work.
The district court affirmed the ALJ; the Seventh Circuit vacated and remanded, finding the ALJ failed to account for progressive deterioration and did not adequately justify discounting the treating physician’s August 2012 opinion.

Issue	Plaintiff's Argument (Walker)	Defendant's Argument (SSA)	Held
Whether substantial evidence supports ALJ's finding that Walker was not disabled at any time from Jan 2008 to Dec 2014 (i.e., correct onset date)	Onset may have occurred around mid-2012; record (treatment notes, Dr. Goudy, Walker's testimony) shows progressive worsening supporting earlier onset	Totality of evidence from 2008–2014 shows recovery and capacity for limited sedentary work until 2014	Vacated; ALJ erred by treating the period as uniform and failing to infer onset per SSR 83-20 principles; remand to determine whether onset was around mid-2012
Whether ALJ gave adequate "good reasons" for giving only partial weight to treating physician Dr. Goudy’s August 2012 opinion	Dr. Goudy was treating physician and contemporaneously documented worsening dizziness, balance, memory, and prognosis; his opinion deserved controlling/greater weight	ALJ discounted Goudy because notes relied on claimant reports, lacked consistent documentation of severe symptoms until later, and conflicted with Dr. Roy’s April 2012 evaluation	Vacated; ALJ’s reasons were not supported by substantial evidence—needed to explain impact of Goudy’s later, specific findings and reconcile them with other evidence on remand

Richardson v. Perales, 402 U.S. 389 (discusses substantial-evidence standard for administrative findings)
Elder v. Astrue, 529 F.3d 408 (court may not reweigh evidence; standard of review)
Scheck v. Barnhart, 357 F.3d 697 (use of SSR 83-20 when determining onset date after disability finding)
Briscoe ex rel. Taylor v. Barnhart, 425 F.3d 345 (articulates SSR 83-20 factors for onset-date inference)
Schaaf v. Astrue, 602 F.3d 869 (treating-physician rule; ALJ must give good reasons to reject treating opinion)