Summary
This Seventh Circuit opinion reviews a district court's affirmation of an Administrative Law Judge's denial of Social Security disability benefits to Jada Padua, who claimed disability based on fibromyalgia, chronic fatigue, depression, and anxiety. Applying a deferential substantial evidence standard, the court concludes that the ALJ properly discounted the treating physicians' extreme limitations and adequately assessed the claimant's residual functional capacity. The appellate court finds no reversible error and affirms the lower court's judgment.
Topics
Practice areas
Questions Presented
- Whether the ALJ’s assessment of Padua’s fibromyalgia and work‑capacity limitations was supported by substantial evidence
- Whether the ALJ properly weighed the opinions of Padua’s treating physicians under the governing regulations
Holdings
- The ALJ’s assessment of Padua’s fibromyalgia and the conclusion that she could perform limited light work are supported by substantial evidence, and the decision is affirmed.
- The ALJ properly gave less controlling weight to the treating physicians’ opinions because of internal inconsistencies, lack of specialist expertise, and because a chiropractor is not an acceptable medical source under the regulations.
Key quotations
“We find that the ALJ built the required “accurate and logical bridge” between the record and the conclusion that Padua remains capable of performing a very limited range of light work.” (at 13)
Factual background
Padua, a 45‑year‑old with fibromyalgia, chronic fatigue, depression, and anxiety, sought disability benefits. She had a history of varied employment and received treatment from Dr. Carpenter (internist) and Dr. Pendolino (chiropractor). The ALJ concluded she was not disabled under the Social Security Act and that jobs existed in the national economy she could perform.
Procedural history
Padua applied for Social Security disability benefits and was denied by an Administrative Law Judge (ALJ). The district court affirmed the ALJ's decision, finding substantial evidence. Padua appealed to the Seventh Circuit.