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7th Circuit affirms denial of disability benefits

July 20, 2017

The 7th Circuit Court of Appeals has affirmed the denial of a woman’s application for disability benefits after finding an administrative law judge properly determined the woman’s medical impairments did not prevent her from working certain jobs.   

After Gotoimoana Summers was fired in February 2012 from her job as a production-line worker in Elkhart, she applied for disability insurance benefits, alleging she became disabled on the date she was fired. The Social Security Administration denied her application and scheduled a hearing before an administrative law judge at Summers’ request.

During the hearing, Summers testified she was unable to work due to headaches, difficulty breathing, atrial fibrillation and dizziness with blackouts. She also submitted medical evidence showing she suffered from depression, anxiety, obesity and sleep apnea.

Summers eventually admitted to the ALJ that she had been fired from her previous job and also retracted her testimony that she had never used marijuana. Further, a vocational expert testified that an individual who was limited to a restricted range of light work would have been able to perform Summers’ previous jobs.

The ALJ then issued a written decision concluding that despite her medical impairments, Summers retained the Residual Functional Capacity (RFC) to perform a substantially limited range of light work, including her previous job as an assembler. The judge also found Summers was “not entirely credible” and, thus, determined she was not disabled from the time of her alleged onset date through the date of the decision.

The Social Security Appeals Council and commissioner upheld the ALJ’s decision, as did the U.S. District Court for the Northern District of Indiana. The 7th Circuit Court of Appeals also agreed with the ALJ’s decision, writing in a Wednesday opinion that the RFC assessment was supported by substantial evidence, as the limitations the ALJ described “generously account for the functional limitations that could reasonably be expected to result from Summers’s medical impairments.”

Similarly, Judge Daniel Manion wrote the ALJ adequately developed the record in the case and properly considered Summer’s obesity as a “severe impairment.” Further, although Summers was diagnosed with atrial fibrillation, she had no heart attacks or coronary artery disease, so the ALJ properly determined she was not temporarily disabled on that basis, the judge said.

Finally, considering Summers’ various inconsistent statements during the hearing, the 7th Circuit determined the ALJ did not commit reversible error by finding her “not entirely credible.” Thus, the denial of Summers’ disability benefits was affirmed.

The case is Gotoimoana Summers v. Nancy A Berry Hill, Acting Commissioner of Social Security, 16-3849.

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