Justia U.S. 7th Circuit Court of Appeals Opinion Summaries

Claudette Rabdeau sought disability benefits under the Social Security Act, claiming that her cervical spine disorder, severe headaches, and mental impairments rendered her unable to work since June 2014. Medical records showed that while Rabdeau experienced significant pain and frequent headaches beginning in 2014, her symptoms were generally well-managed through medication and treatments, including Botox injections, until May 2018, when her condition worsened and became disabling.Rabdeau’s initial application for benefits was denied by an Administrative Law Judge (ALJ) in 2018, who found she could still work during the relevant period. After a remand from the Social Security Administration Appeals Council for further consideration of her migraines and mental impairments, the same ALJ issued a partially favorable decision in 2019, finding Rabdeau disabled only from May 9, 2018 onward. Rabdeau appealed the unfavorable portion, and the Appeals Council remanded the case again in 2021, citing insufficient evaluation of evidence regarding her headaches prior to May 2018. On remand, a different ALJ reviewed the case and, after considering testimony from a new vocational expert, denied benefits for the period before May 2018, finding her impairments were not severe enough to be disabling. The United States District Court for the Eastern District of Wisconsin affirmed this decision.The United States Court of Appeals for the Seventh Circuit reviewed the district court’s affirmance, applying the “substantial evidence” standard. The court held that the second ALJ was not required to address the prior ALJ’s findings as long as the decision was supported by substantial evidence. The Seventh Circuit found that the medical record supported the ALJ’s conclusion and affirmed the denial of benefits for the period before May 2018. View "Rabdeau v. Bisignano" on Justia Law

Two children, E.R. and G.S., have severe, complex medical conditions that require constant, skilled care. Their mothers, who are their primary caregivers and sole financial supporters, have been trained by medical professionals to provide the necessary care at home. For years, Indiana’s Medicaid program reimbursed these mothers for providing “attendant care services” under a waiver program designed to keep individuals out of institutions. In July 2024, the Indiana Family and Social Services Administration (FSSA) implemented a policy change that would make parents ineligible to be paid providers of attendant care for their children, threatening to force E.R. and G.S. into institutional care due to the lack of available in-home nurses.The Indiana Protection and Advocacy Services Commission, along with E.R. and G.S., sued to block the policy change and require FSSA to secure in-home nursing. The United States District Court for the Southern District of Indiana initially granted a preliminary injunction requiring FSSA to take steps to obtain in-home nurses and to pay the mothers for a different, lower-paid service. After further proceedings, the court modified its order, ultimately requiring FSSA to pay the mothers for attendant care at the previous rate until in-home nursing could be secured.The United States Court of Appeals for the Seventh Circuit affirmed the district court’s October 1 injunction. The court held that the plaintiffs are likely to succeed on their claims under the Americans with Disabilities Act’s integration mandate, which requires states to provide services in the most integrated setting appropriate. The court found that prohibiting the mothers from providing paid attendant care placed the children at serious risk of institutionalization and that FSSA had not shown that allowing such care would fundamentally alter the Medicaid program or violate federal law. The case was remanded for further proceedings. View "Indiana Protection and Advocacy Services Comm'n v Indiana Family and Social Services Administration" on Justia Law

Jonathan Cain applied for supplemental security income (SSI) due to severe impairments, including degenerative disc disease, migraine headaches, obesity, depression, and anxiety. Despite his conditions, an administrative law judge (ALJ) determined that Cain could perform certain types of work and denied his disability benefits. Cain challenged this decision in federal court.The United States District Court for the Southern District of Indiana affirmed the ALJ's decision, holding that substantial evidence supported the ALJ's conclusion. The court found that the ALJ met the minimal articulation requirements in assessing the medical evidence and did not err in relying on the vocational expert's testimony.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court held that the ALJ's decision was supported by substantial evidence. The ALJ adequately evaluated the medical opinions of Cain's treating physician, Dr. Amanda Williams, and the state agency psychologists, Dr. Joelle Larsen and Dr. Ken Lovko. The ALJ also properly relied on the vocational expert, Thomas Dunleavy, who provided a reliable basis for his job number predictions. The court concluded that the ALJ did not commit legal error and affirmed the district court's judgment. View "Cain v Bisignano" on Justia Law

Jada Padua applied for Social Security benefits, claiming disability due to fibromyalgia, chronic fatigue, depression, and anxiety. An administrative law judge (ALJ) denied her benefits, concluding that she was not disabled as defined by the Social Security Act and that jobs existed in significant numbers in the national economy that she could perform. Padua challenged the agency’s denial in federal court, but the district court upheld the ALJ's decision, finding substantial evidence to support it.Padua filed her disability benefits application in November 2010, initially claiming a disability onset date of July 2008, later amended to November 2010. After an initial denial and a remand by a magistrate judge in February 2016, the ALJ held a second hearing in August 2016. The ALJ determined that Padua was not disabled under the Social Security Act, finding that her impairments did not meet a listing for presumptive disability and that she had the residual functional capacity (RFC) to perform light work with additional limitations. The ALJ discounted Padua’s complaints of extreme pain and fatigue, noting inconsistencies with her daily activities and the overall medical record. The ALJ also gave little weight to the opinions of her treating physicians, Drs. Carpenter and Pendolino, finding them inconsistent with the evidence.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s decision. The court held that the ALJ’s assessment of Padua’s fibromyalgia and the opinions of Drs. Carpenter and Pendolino were supported by substantial evidence. The court found that the ALJ reasonably considered the objective medical evidence, treatment history, and daily activities in determining Padua’s RFC. The court also concluded that the ALJ provided adequate reasons for discounting the treating physicians’ opinions and that the RFC determination was supported by substantial evidence. View "Padua v. Bisignano" on Justia Law

Christian Arnold retained Binder & Binder in April 2018 to represent him in a claim for disability benefits under the Social Security Act. After the Commissioner of Social Security denied his claim, Arnold appealed to the district court, which remanded the case to the agency. An administrative law judge later determined Arnold was entitled to $160,797.10 in past-due benefits. Binder then moved for attorneys' fees under 42 U.S.C. § 406(b), seeking twenty-five percent of the retroactive benefits, amounting to $40,199.27. The district court awarded Binder $16,920, reducing the fee based on an effective hourly rate of $600.The United States District Court for the Central District of Illinois initially awarded Binder $16,920, despite the contingency fee agreement. Binder appealed, and the United States Court of Appeals for the Seventh Circuit held that the district court abused its discretion by not anchoring its reasonableness analysis on the contingency fee agreement. The case was remanded for further proceedings. On remand, the district court again awarded $16,920, maintaining that the contingency fee should be reduced to reflect a more reasonable effective hourly rate. Binder appealed once more.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the district court abused its discretion by inadequately explaining its decision to reduce Binder’s fees. The appellate court emphasized that the district court must begin with the contingency fee agreement and consider relevant factors, such as the plaintiff’s satisfaction and the attorney’s expertise. The appellate court reversed the district court’s decision and remanded with instructions to order the Social Security Administration to remit attorneys’ fees at Binder’s requested amount of $34,199.27. View "Arnold v. Bisignano" on Justia Law

Donald Thorpe sought disability benefits, claiming that his health issues rendered him unable to work. The Administrative Law Judge (ALJ) denied his claim, relying on the testimony of a vocational expert. Thorpe appealed to the district court, which affirmed the ALJ’s decision, stating that Thorpe forfeited any challenge to the expert testimony by failing to object timely and that the decision was supported by substantial evidence.The district court found that Thorpe did not object to the vocational expert’s testimony during the hearing or in a post-hearing brief, thus forfeiting his right to challenge it. The court also determined that the ALJ’s decision was based on substantial evidence, including the expert’s testimony, which was consistent with the Dictionary of Occupational Titles (DOT) and supported by the expert’s qualifications and experience.The United States Court of Appeals for the Seventh Circuit reviewed the case and agreed with the district court. The court held that Thorpe forfeited his ability to challenge the expert’s testimony by not objecting during the hearing. The court also found that the ALJ’s decision was supported by substantial evidence, as the expert’s testimony had sufficient indicia of reliability, including consistency with the DOT and the expert’s qualifications.The Seventh Circuit affirmed the district court’s decision, concluding that the ALJ did not err in relying on the vocational expert’s testimony to determine that Thorpe was not disabled and could find other gainful employment. View "Thorpe v Bisignano" on Justia Law

Ferida H. Moy suffers from severe PTSD due to her experiences during the Yugoslav Wars. She applied for disability insurance benefits and supplemental security income, citing her PTSD and related mental health issues. An administrative law judge (ALJ) denied her application, finding that she had the residual functional capacity to perform simple, routine tasks with minimal contact with supervisors and co-workers. This decision was upheld by the district court, leading Moy to appeal.The ALJ found that Moy had moderate limitations in concentrating, persisting, or maintaining pace but concluded that she could work at a consistent production pace. The ALJ's decision was based on the testimony of a vocational expert who stated that a person with Moy's limitations could work as a dining room attendant, bus person, scrap sorter, industrial cleaner, or dishwasher. However, the vocational expert also testified that regular absences or being off-task for more than 15% of the workday would result in job loss. The ALJ's decision was affirmed by the district court.The United States Court of Appeals for the Seventh Circuit reviewed the case and found that the ALJ failed to build a logical bridge between Moy's limitations and the conclusion that she could work at a consistent production pace. The court noted that the ALJ's determination did not adequately account for Moy's limitations in concentration, persistence, and pace. The court emphasized that the ALJ's reasoning was internally inconsistent and did not reflect Moy's documented symptoms and treatment needs. Consequently, the Seventh Circuit vacated the judgment and remanded the case to the Commissioner of Social Security for further consideration consistent with its opinion. View "Moy v Bisignano" on Justia Law

Alicia Rae Pufahl applied for disability insurance benefits from the Social Security Administration in August 2012, citing limitations due to Wegener’s granulomatosis, depression, pulmonary disease, back injury, bipolar disorder, and excessive fatigue. She needed to establish disability between August 8, 2011, and December 31, 2016. Her application was initially denied in November 2012, followed by several unfavorable decisions from Administrative Law Judges (ALJs), appeals, and remands. The most recent ALJ decision concluded that she was not disabled during the relevant period, and the district court affirmed this decision.The United States District Court for the Eastern District of Wisconsin affirmed the ALJ’s decision, finding that substantial evidence supported the agency’s determination. The Appeals Council denied further review, making the ALJ’s decision the final decision of the Commissioner of Social Security.The United States Court of Appeals for the Seventh Circuit reviewed the case and affirmed the district court’s judgment. The court held that the ALJ properly weighed the medical opinion evidence, including the opinions of Ms. Pufahl’s neurologist, primary care provider, and psychiatrist, and found substantial evidence supporting the ALJ’s decision to not give controlling weight to these opinions. The ALJ’s evaluation of Ms. Pufahl’s subjective complaints was not patently wrong, as it was supported by specific reasons and evidence. Additionally, the hypothetical question posed to the vocational expert (VE) sufficiently accounted for Ms. Pufahl’s mental limitations, including her ability to maintain attention and concentration for two-hour segments. The court concluded that the ALJ’s decision was supported by substantial evidence and affirmed the district court’s judgment. View "Pufahl v Bisignano" on Justia Law

Dennis Jones, a 42-year-old part-time grocery store cashier, applied for Social Security disability benefits, claiming that conditions related to his premature birth, including a cerebral hematoma, had worsened and prevented him from working full-time. The Social Security Administration denied his application, and Jones requested an administrative hearing. An Administrative Law Judge (ALJ) found that Jones had the residual functional capacity to perform light work with certain limitations and concluded that he was not disabled.The United States District Court for the Northern District of Illinois affirmed the ALJ's decision. Jones then appealed to the United States Court of Appeals for the Seventh Circuit, arguing that the ALJ failed to properly evaluate a statement from Dr. James Runke, a consultative examiner, which Jones contended was a medical opinion.The Seventh Circuit agreed with Jones that Dr. Runke's statement, which indicated that Jones's pain and joint strain limited him to working 20 hours per week, constituted a medical opinion under the 2017 revised regulations. However, the court held that the ALJ was not required to evaluate the persuasiveness of this medical opinion because it addressed an issue reserved to the Commissioner of Social Security—whether Jones was capable of performing regular or continuing work. Consequently, the ALJ had no obligation to provide an analysis of Dr. Runke's statement. The Seventh Circuit affirmed the district court's decision, upholding the denial of benefits. View "Jones v Dudek" on Justia Law

Christine Swiecichowski worked in a warehouse for over thirty years until 2018, when she quit due to increasing symptoms and pain from fibromyalgia, depression, issues with her right arm and wrist, and spinal disorders. She applied for disability benefits in October 2018, claiming she was disabled from October 16, 2018. Her application and testimony described debilitating pain that limited her ability to work and perform daily activities.The Administrative Law Judge (ALJ) denied her application in June 2020, following the Social Security Administration's five-step process for determining disability. The ALJ found that Swiecichowski had severe impairments, including fibromyalgia, but concluded that none were automatically disabling. The ALJ determined that her residual functional capacity (RFC) allowed her to perform light work with some restrictions. The ALJ discounted her subjective complaints of pain, citing mixed clinical findings and her ability to perform some daily activities. The Appeals Council denied her request for review, making the ALJ's decision final. The United States District Court for the Eastern District of Wisconsin affirmed the ALJ's decision.The United States Court of Appeals for the Seventh Circuit reviewed the case. The court found that the ALJ did not adequately follow the Social Security Administration's guidance on evaluating fibromyalgia, which requires a longitudinal review of the claimant's symptoms due to their waxing and waning nature. The ALJ's decision did not sufficiently consider the numerous medical visits and reports of pain over time. The court vacated the judgment affirming the denial of benefits and remanded the case for further proceedings consistent with its opinion. View "Swiecichowski v Dudek" on Justia Law