Zanoni v. Saul, 3:18-cv-50408

C.M. was found disabled in 2008 (age 3+) for developmental delays and autism; a continuing disability review in 2015 found medical improvement and ended benefits as of March 1, 2015.
At evaluation in October 2015, psychologist Dr. Mark Langgut tested C.M. (IQ composite 84) and diagnosed trauma reaction, adjustment disorder, and childhood abuse/neglect effects.
The ALJ held a hearing in Feb 2018 and issued a decision in March 2018 finding some limitations but none "marked" in any of the six child-function domains, so C.M. did not functionally equal a listing.
The ALJ gave great weight to six teacher questionnaires (one from 2015, five from 2018) as teachers observed classroom functioning daily; none rated "serious problems" in the disputed domains.
Plaintiff argued the ALJ cherry-picked the checkbox ratings while discounting handwritten paragraph comments that, she says, indicate marked limitations; plaintiff also pointed to Rosecrance therapy notes, absence of a 2014 IEP, C.M.’s testimony, and state reviewer opinions.
The district court affirmed: it found the ALJ reasonably read the teacher forms as consistent, properly weighed therapy notes and other evidence, and that remand was not warranted.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ cherry-picked teacher questionnaires	ALJ relied on checkbox ratings and downplayed handwritten comments showing marked limits	ALJ reasonably read handwritten comments as consistent with ratings; no actual conflict	Court: ALJ’s commonsensical reading reasonable; no remand
Whether lack of 2014 IEP undermines ALJ decision	Absence of IEP does not prove no marked impairments	ALJ did not rely solely on IEP absence; it was one factor among many	Court: Even ignoring IEP point, substantial evidence supports ALJ
Whether therapy notes (Rosecrance) show greater impairment	Therapy records show persistent, more serious deficits supporting marked limits	Records show symptom fluctuation and contain observations consistent with ALJ findings	Court: ALJ reasonably weighed therapy notes; no error
Whether C.M.’s testimony that he "argues" with teachers supports marked limits	Testimony indicates behavioral problems and conflicts with teachers	Testimony was vague, brief, prompted, and not integrated with teacher reports	Court: Testimony insufficient to overturn ALJ
Whether reliance on state agency reviewers was improper	Argues ALJ relied heavily on state reviewers	ALJ did not base decision solely on those opinions; decision rests on teacher reports	Court: Non-issue; decision supported without relying on them

Hopgood v. Astrue, 578 F.3d 696 (7th Cir. 2009) (teacher questionnaires can be important evidence and require adequate consideration)
Jones v. Astrue, 623 F.3d 1155 (7th Cir. 2010) (Court gives ALJ’s opinion a commonsensical reading)
Buckhanon v. Astrue, [citation="368 Fed. App'x 674"] (7th Cir. 2010) (ALJ not required to address every piece of evidence individually)
Shideler v. Astrue, 688 F.3d 306 (7th Cir. 2012) (no remand when reasonable minds can differ over disability determination)