Summary
This Seventh Circuit opinion reviews a district court's affirmation of a Social Security Administration Administrative Law Judge's decision denying disability benefits to Claudette Rabdeau for the period prior to May 2018. The court evaluates whether the second ALJ's ruling was supported by substantial evidence, specifically addressing the appellant's claim that the ALJ improperly ignored prior findings regarding her monthly work absences. Finding that the medical record adequately supported the conclusion that Rabdeau's symptoms were not disabling before May 2018, the court affirms the lower court's judgment.
Topics
Practice areas
Questions Presented
- Whether ALJ Freyberg’s denial of pre‑May 2018 benefits was supported by substantial evidence
- Whether an ALJ must address a prior ALJ’s findings on remand
Holdings
- The court affirmed the district court, finding that ALJ Freyberg’s decision was supported by substantial evidence and therefore not reversible.
- An ALJ is not required to discuss every prior finding so long as the decision is supported by substantial evidence.
Key quotations
“We will reverse an ALJ’s decision only if it is the result of an error of law or it is not supported by substantial evidence.” (at 8)
“the evidence f[ell] far from supporting the second ALJ’s finding.” (at 9)
Factual background
Rabdeau suffered cervical spine degeneration, severe headaches, and anxiety beginning in 2014. Over several years her headaches fluctuated in frequency and intensity, responding to various medications and Botox injections, but were generally well‑controlled by 2018. Medical records showed normal cognitive and motor function throughout the period.
Procedural history
Rabdeau applied for SSDI benefits in 2015. An ALJ denied the claim, the district court remanded. Subsequent ALJs on remand found disability only from May 2018 onward. The district court affirmed the ALJ’s denial of pre‑May 2018 benefits. Rabdeau appealed to this circuit.