Yum v. O'Malley
1:22-cv-01452
N.D. Ill.Nov 18, 2024Background
- Plaintiff Young K.Y. applied for Supplemental Security Income (SSI) in September 2019, alleging disability due to back and neck degenerative disc disease and related symptoms, with alleged onset in June 2018.
- Plaintiff was 55 as of the application date, a classification called "person of advanced age," and had work experience as a restaurant owner and sales representative, but no substantial gainful activity in 2019–2020.
- The Social Security Administration (SSA) denied the application initially and on reconsideration. Plaintiff appealed and testified (with counsel and interpreter) before an Administrative Law Judge (ALJ).
- The ALJ found Plaintiff's impairments "severe" but not disabling and concluded Plaintiff could perform a reduced range of light work, including her past work as sales manager; thus, she was "not disabled."
- The Appeals Council denied review, making the ALJ decision final and reviewable by the District Court.
- Plaintiff argued the ALJ erred in weighing medical opinion evidence and in assessing Plaintiff's credibility; the matter came before the court on cross-motions for summary judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the ALJ properly weighed medical | ALJ erred by relying on her own lay interpretation of MRI results and | ALJ correctly found state agency reviewer's opinion consistent | ALJ erred by playing doctor and selecting evidence |
| opinion evidence in RFC assessment | rejecting more restrictive medical opinion without proper explanation | with clinical evidence and Plaintiff’s reported activities | without adequate medical basis; remand required |
| Whether ALJ properly evaluated | ALJ improperly discounted Plaintiff’s subjective pain and limitations | ALJ properly assessed Plaintiff’s credibility against record | No specific reversible error found, but reevaluation |
| Plaintiff's subjective testimony | recommended on remand |
Key Cases Cited
- Biestek v. Berryhill, 139 S. Ct. 1148 (substantial evidence standard defined as that which a reasonable mind accepts as adequate)
- Akin v. Berryhill, 887 F.3d 314 (7th Cir. 2018) (ALJs may not interpret raw medical data without medical expert input)
- Spiva v. Astrue, 628 F.3d 346 (7th Cir. 2010) (harmless error for remand only if outcome would not change)
- Haynes v. Barnhart, 416 F.3d 621 (7th Cir. 2005) (describing SSA appeals process and judicial review standard)
- Warnell v. O’Malley, 97 F.4th 1050 (standard for reviewing ALJ decisions and the requirement of a logical bridge)