Williams ex rel. Townsend v. Colvin
757 F.3d 610
7th Cir.2014Background
- Townsend applied for SSD/SSI in Feb 2003 at age 44, alleging disability since May 2002 due to fibromyalgia and psychiatric ailments; she died before the 2012 decision, and her father Gene Williams pursued the appeal.
- Initial ALJ hearing (Nov 2004) found no total disability; after remand (May 2007) a new hearing occurred with townsend and her father testifying; a 2011 hearing by another ALJ resulted in a finding of total disability beginning Nov 1, 2008.
- Medical evidence showed fibromyalgia and chronic pain with edema, headaches, tremors, falls, and psychosocial issues (PTSD, anxiety, depression) corroborated by multiple doctors and parents’ testimony.
- Psychiatric assessments included a GAF of 65 (mild symptoms) and later GAFs of 45 (severe impairment), with concern that the later ratings reflected pain and functional loss rather than purely psychiatric illness.
- ALJ’s analysis omitted combined impairment effects, treated physical and mental impairments in isolation, discounted credibility of Townsend’s symptoms without independent testing, and failed to consider psychosomatic influences and other records; order remanded to determine onset date consistent with last insured status.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ erred by not considering the combined effects of all impairments. | Williams argues combined impairments yield disability. | Townsend's combined effects not properly examined was not demonstrated. | Reversed for remand to reassess onset considering all impairments. |
| Whether the ALJ properly evaluated Townsend’s credibility and medical evidence. | Townsend’s symptoms and limitations were credible despite inconclusive cause. | Limitations not credibly established due to lack of medical diagnoses. | Reversed for remand to re-evaluate credibility and medical evidence. |
| Whether on remand the onset date should be earlier than Nov 1, 2008, potentially benefiting the estate. | Onset likely May 1, 2002; earlier insured period. | Current onset date November 2008 was upheld. | Remand to determine an earlier onset date if supported by the record. |
Key Cases Cited
- Green-Younger v. Barnhart, 335 F.3d 99 (2d Cir.2003) (disability analysis must consider combined impairments; not solely medical diagnosis)
- Smolen v. Chater, 80 F.3d 1273 (9th Cir.1996) (pain and symptoms may be disabling despite lack of objective medical evidence)
- McLaughlin v. Secretary of Health, Education & Welfare, 612 F.2d 701 (2d Cir.1980) (medical evidence may be inconclusive yet disability can exist)
- Denton v. Astrue, 596 F.3d 419 (7th Cir.2010) (Holistic/combined impairment analysis required under SSA regulations)
- Cichocki v. Astrue, 729 F.3d 172 (2d Cir.2013) (per curiam; reiterates need for holistic impairment consideration)