Hall v. Berryhill

Summary

The Seventh Circuit affirmed the denial of Social Security disability benefits in *Hall v. Berryhill*, 906 F.3d 640 (7th Cir. 2018). The court held that substantial evidence supported the ALJ's decision to discount the treating physician's opinion under 20 C.F.R. § 404.1527(c)(2) due to inconsistencies with the record, and that the ALJ's credibility determination was not patently wrong. The court found that any errors in the ALJ's reasoning (speculating about sympathy, criticizing the referral source) were harmless. The claimant also waived underdeveloped arguments regarding his RFC and failed to meet his burden for Listing 1.04A.

Holdings

1. The ALJ's discounting of Dr. Luken's opinion was supported by substantial evidence because the opinion was inconsistent with the opinions of Drs. Miz, Hutchinson, and Heller, all of whom had access to the 2008 functional capacity evaluation that Dr. Luken lacked. The ALJ's improper comments about sympathy and the claimant's choice of doctor did not undermine this conclusion.
2. The ALJ's credibility determination was not patently wrong because the ALJ provided specific, evidence-based reasons: Hall's inconsistent statements about his limitations, evidence of normal gait and range of motion, a physical therapist's report of symptom exaggeration, and Hall's successful use of pain medication without side effects.
3. Hall failed to meet his burden to show that his impairment met or medically equaled Listing 1.04A, as he did not provide evidence of limitation of motion of the spine and motor loss with sensory or reflex loss.

Questions Presented

1. Whether the ALJ properly applied the treating-physician rule to Dr. Luken's opinion.
2. Whether the ALJ adequately supported his credibility determination regarding Hall's symptoms.

Disposition

affirmed