Jacoby v. Barnhart

Summary

The Seventh Circuit affirmed the denial of disability insurance benefits to Donald Jacoby, who alleged that arthritis in his left knee prevented him from working. The court held that the ALJ properly discounted a treating physician’s later questionnaire responses, found Jacoby’s allegations of disabling pain not fully credible, and determined that he could perform light work. The court also upheld the ALJ’s use of vocational evidence and the Medical-Vocational Guidelines.

Holdings

1. The ALJ properly refused to give controlling weight to the treating physician's October 1999 questionnaire responses because those opinions were inconsistent with the physician's contemporaneous treatment notes and lacked support in medical findings.
2. The ALJ properly discounted Jacoby's subjective complaints of disabling pain because the ALJ considered the required factors and the credibility determination was supported by the record and was not patently wrong.
3. The ALJ properly found that Jacoby could perform light work with specified nonexertional restrictions and was not required to obtain additional vocational-expert testimony because the limitations did not significantly erode the light-work occupational base.

Questions Presented

1. Whether the ALJ properly declined to give controlling weight to the treating physician's later questionnaire responses.
2. Whether the ALJ properly discounted Jacoby's testimony regarding disabling pain.
3. Whether the ALJ properly determined that Jacoby retained the capacity to perform light work with specified nonexertional limitations.
4. Whether the ALJ was required to obtain vocational-expert testimony to assess the effect of Jacoby's nonexertional limitations on the occupational base.

Disposition

affirmed