Warkel v. Bisignano
1:22-cv-06520
N.D. Ill.Jun 27, 2025Background
- Plaintiff Jacob W. filed for Social Security disability insurance benefits, alleging disability from physical and mental impairments following a 2015 car accident.
- An initial ALJ decision denied benefits; this was remanded by the district court for further evaluation of subjective symptoms, opinion evidence, and residual functional capacity (RFC).
- On remand, ALJ Studzinski again denied benefits, finding that while Jacob had several severe impairments, he was still able to perform certain light jobs in the national economy.
- Jacob appealed, arguing the ALJ erred in evaluating both his mental and physical residual functional capacities and failed to properly evaluate his subjective symptoms.
- The district court reviewed the parties’ summary judgment motions, focusing on whether the ALJ's decision was supported by substantial evidence and legally sufficient reasoning.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Adequacy of RFC for mental impairments | ALJ failed to connect RFC limitations to evidence, missing qualitative & stress-related limits | RFC reflects medical evidence; no qualitative interaction limits needed | RFC supported by substantial evidence; no qualitative restrictions warranted |
| Interaction limitations (coworkers/supervisors) | ALJ didn't justify limited interactions and failed to impose qualitative restrictions | No medical evidence supports need for qualitative restrictions | No evidence required such restrictions; ALJ’s quantitative limits sufficient |
| Leg elevation limitation for ankle impairment | ALJ erred by omitting need for periodic leg elevation | Sparse medical record on leg elevation; only two mentions in record | ALJ’s omission supported; mentions insufficient to compel RFC inclusion |
| Manipulative limitations due to hand issues | ALJ downplayed hand problems and imposed too few manipulative restrictions | State doctors found no manipulative limits; ALJ added reasonable restrictions | ALJ’s RFC accounted for credible limitations based on evidence |
| ALJ’s analysis of subjective symptoms | Failed to properly credit Plaintiff’s pain and mental symptoms | ALJ weighed testimony, treatment, and activities adequately | Not patently wrong; ALJ’s symptom analysis stands |
Key Cases Cited
- Young v. Sec'y of Health & Human Servs., 957 F.2d 386 (7th Cir. 1992) (outlines the 5-step SSA disability determination framework)
- Biestek v. Berryhill, 587 U.S. 97 (2019) (defines standard for "substantial evidence" in Social Security cases)
- Prill v. Kijakazi, 23 F.4th 738 (7th Cir. 2022) (reviewing court does not rubber-stamp ALJ decisions; must assess legal sufficiency)
- Reynolds v. Kijakazi, 25 F.4th 470 (7th Cir. 2022) (affirming ALJ where record did not support qualitative interaction limitations)
- Murphy v. Colvin, 759 F.3d 811 (7th Cir. 2014) (ALJ’s symptom evaluation is only reversible if patently wrong)
- Jozefyk v. Berryhill, 923 F.3d 492 (7th Cir. 2019) (RFC with simple, routine tasks and limited interaction sufficient for moderate cognitive & social limitation)