Loveless v. Colvin

Summary

The Seventh Circuit affirmed the denial of Kevin Loveless’s application for Social Security Disability Insurance benefits. The court held that the administrative law judge reasonably discounted the treating physician’s restrictive opinion and assessed Loveless’s testimony in light of the medical evidence, daily activities, and conservative treatment. The court concluded that substantial evidence supported the residual functional capacity assessment and denial of benefits.

Holdings

1. The ALJ properly declined to give controlling or greater weight to Dr. Cusack's January 2013 opinion because it was contradicted by objective medical evidence, inconsistent with other evidence, and rested substantially on Loveless's subjective complaints.
2. The ALJ was not required to accept Dr. Cusack's conclusory October 2012 statement that Loveless could not work because the ultimate question of ability to work is reserved to the Commissioner.
3. The ALJ's use of routinely criticized boilerplate language did not require remand because the ALJ supported the credibility assessment with specific evidence.
4. The ALJ properly considered Loveless's daily activities and work history as factors bearing on the credibility and severity of his symptom allegations; neither factor was dispositive.
5. The ALJ did not err by declining to impose additional residual-functional-capacity restrictions for Loveless's diabetes and hand impairments because the record did not contain medical evidence justifying further limitations.

Questions Presented

1. Whether the ALJ properly discounted the treating physician's January 2013 opinion because it was unsupported by objective medical evidence, inconsistent with the record, and based largely on Loveless's subjective complaints.
2. Whether the ALJ was required to adopt or separately discuss the treating physician's conclusory October 2012 statement that Loveless could not work.
3. Whether the ALJ's use of boilerplate language in evaluating Loveless's credibility required remand.
4. Whether the ALJ improperly relied on Loveless's daily activities and failed to account for his work history when evaluating his testimony.
5. Whether the ALJ failed to include additional limitations arising from Loveless's diabetes and hand impairments in the residual functional capacity assessment.

Disposition

affirmed