YOUNG v. COLVIN
1:13-cv-00526
S.D. Ind.Nov 3, 2014Background
- Diana Young (b. 1960) applied for Disability Insurance Benefits alleging onset June 30, 2006; ALJ denied benefits and Appeals Council denied review, making decision final.
- ALJ found severe impairments: degenerative lumbar disc disease, shoulder degenerative joint disease, obesity, and COPD; past work included janitor and teacher’s aide.
- Young sought treatment episodically; record includes consultative exams, orthopedic evaluations, and a one-time independent examiner (Dr. Siegel) who limited standing/walking and lifting.
- ALJ relied on testifying medical expert and state agency physician who opined Young could perform light work (including standing/walking up to six hours/day); ALJ discounted Dr. Siegel’s restrictive opinion as inconsistent with the record and non-treating.
- Young submitted post-decision evidence (Dr. Trusler letter on shoulder restrictions) and argued the ALJ erred in credibility assessment, in treating her ankle impairment as non-severe, and in failing to account for obesity’s effect on limitations.
- District court affirmed: ALJ’s RFC and credibility findings supported by substantial evidence; new evidence did not warrant remand; obesity was considered and accommodated in RFC.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether ALJ erred in finding Young can meet walking/standing for light work | Young: Dr. Siegel limits standing/walking and lifting below light work thresholds | Commissioner: Dr. Siegel is a non‑treating consultant and his opinion conflicts with treating/other examiners and testifying experts | Court: ALJ permissibly discounted Dr. Siegel; substantial evidence supports light‑work finding |
| Whether ALJ improperly discredited Young’s subjective complaints | Young: ALJ failed to consider all credibility factors and improperly penalized her for declining surgery/therapy | Commissioner: ALJ cited objective findings, treatment choices, inconsistent exam reports, and activities of daily living as valid reasons | Court: ALJ provided specific, record‑supported reasons; credibility finding upheld |
| Whether ALJ erred by finding ankle impairment non‑severe | Young: Ankle limitations support greater restrictions | Commissioner: Ankle fracture predated onset and record/testimony shows no 12‑month disabling residuals | Court: ALJ reasonably found ankle non‑severe; no durational evidence of disabling residuals |
| Whether Appeals Council should remand for new shoulder opinion | Young: Dr. Trusler’s post‑decision letter imposed upper‑extremity restrictions warranting remand | Commissioner: Letter is not new as underlying evidence existed, and RFC already limited overhead lifting | Court: Evidence not a basis for sentence‑six remand; RFC accommodated comparable restrictions |
| Whether ALJ failed to account for obesity | Young: ALJ did not adequately assess obesity’s exacerbating effects (e.g., dietary limits due to GERD) | Commissioner: ALJ found obesity severe and incorporated its effects by limiting to light work; testifying expert agreed | Court: ALJ addressed obesity and accounted for combined effects in RFC; no additional restrictions supported |
Key Cases Cited
- Barnett v. Barnhart, 381 F.3d 664 (7th Cir.) (standard for judicial review: uphold ALJ if correct legal standard and substantial evidence)
- Dixon v. Massanari, 270 F.3d 1171 (7th Cir.) (five‑step sequential evaluation framework)
- Bowen v. Yuckert, 482 U.S. 137 (Sup. Ct.) (claimant bears burden at steps one‑four)
- O'Connor‑Spinner v. Astrue, 627 F.3d 614 (7th Cir.) (ALJ must build a logical bridge between evidence and conclusion)
- Simila v. Astrue, 573 F.3d 503 (7th Cir.) (credibility factors and SSR 96‑7p guidance)
- Schmidt v. Barnhart, 395 F.3d 737 (7th Cir.) (definition of "new" evidence for sentence‑six remand)
- Jens v. Barnhart, 347 F.3d 209 (7th Cir.) (standards for remand under sentence six of 42 U.S.C. § 405(g))
- Prochaska v. Barnhart, 454 F.3d 731 (7th Cir.) (claimant must articulate how obesity limits functioning)
- Young v. Barnhart, 362 F.3d 995 (7th Cir.) (courts must defer to Commissioner when reasonable minds could differ)
- Terry v. Astrue, 580 F.3d 471 (7th Cir.) (review limited; court may not reweigh evidence)