Summary
The United States Court of Appeals for the Seventh Circuit affirmed the district court’s judgment upholding the partial denial of Laurie Yokosh’s Social Security disability benefits for the period from August 14, 2015, through August 31, 2017. The court held that the Administrative Law Judge adequately considered the relevant regulatory factors and reasonably gave little weight to the treating psychologist’s opinion regarding Yokosh’s limitations in performing complex work.
Topics
Practice areas
Questions Presented
- Whether the ALJ adequately considered the regulatory factors and sufficiently articulated supported reasons for giving little weight to the treating psychologist's opinion regarding Yokosh's ability to perform complex work tasks.
- Whether the ALJ's finding that Yokosh's mental impairments were non-severe and that she retained the residual functional capacity to perform her past relevant work was supported by substantial evidence.
Holdings
- The ALJ properly gave little weight to Dr. Matusiak's opinion because the ALJ considered the relevant regulatory factors and provided well-supported reasons, including inconsistencies with other medical opinions, treatment notes, and Yokosh's reported activities, as well as the limited treatment relationship.
- The ALJ's determination that Yokosh was not disabled before September 1, 2017, was supported by substantial evidence and was not the result of legal error.
Key quotations
“And 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, which is ‘such relevant evidence as a reasonable mind might accept as adequate to support a conclusion.’”” (8)
“In short, the ALJ’s decision was more than minimally articulated and well supported, and we “will not substitute our judgment . . . by reweighing the evidence.”” (13)
Factual background
Yokosh stopped working in August 2015, primarily because of chronic back pain and related physical impairments. She had a history of bipolar disorder but had stopped taking psychotropic medication in 2007; later evaluations documented depression and anxiety, with differing opinions about the severity of her mental limitations. Her treating psychologist, Dr. Matusiak, opined that she had substantial limitations in complex work tasks, while other medical experts found no more than mild mental limitations. The ALJ found her mental impairments non-severe before September 1, 2017, and determined that she could perform her past work as a bookkeeper.
Procedural history
Yokosh applied for disability insurance benefits in September 2015. After an initial denial, the district court remanded the case in 2019 pursuant to the parties' stipulation, and a different ALJ subsequently found her disabled beginning November 26, 2017. The Social Security Appeals Council remanded the matter again in 2021 for further consideration of disability before that date. Following a 2022 hearing, the ALJ found Yokosh disabled beginning September 1, 2017, but not before then; the district court affirmed, and the Seventh Circuit affirmed the district court.