10-1314 Campbell v. Astrue

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Public Health
Disability benefits

Where the ALJ ignored portions of a physician’s report suggesting a disability, the denial of disability benefits must be reversed.

“An ALJ may not selectively discuss portions of a physician’s report that support a finding of non-disability while ignoring other portions that suggest a disability. Myles v. Astrue, 582 F.3d 672, 678 (7th Cir. 2009). The ALJ failed to evaluate the entirety of the mental health assessment reviewed by Dr. Powell on December 22, 2005. The ALJ focused her attention on section ‘V. Mental Status,’ instead of considering the six-page report as a whole. The ALJ correctly noted that Campbell’s mental status examination was within normal limits but for a flat affect. But the ALJ ignored the sections for ‘Presenting Problem/Precipitants,’ ‘Diagnostic Formulation,’ and ‘Diagnostic Impression’ that suggest greater mental limitations. The assessment relates Campbell’s self-reported symptoms: daily anxiety, compulsions, daily agitation, daily irritation, and auditory hallucinations that keep him up nightly. In the ‘Diagnostic Formulation’ section, it was noted that Campbell reported continued symptoms of depression, including anxiety, agitation, decreased appetite and sleep, and poor concentration. In addition, the mental health provider also reached his or her own conclusions about Campbell’s mental condition. These are noted under Diagnostic Impression as a mood disorder and a rating of 50 on the GAF Scale, reflecting serious symptoms or any serious impairment in functioning, for example, being unable to keep a job. See DSMV-IV-TR 34. A GAF rating of 50 does not represent functioning within normal limits. Nor does it support a conclusion that Campbell was mentally capable of sustaining work.”

Reversed and Remanded.

10-1314 Campbell v. Astrue

Appeal from the United States District Court for the Northern District of Illinois, Darrah, J., Tinder, J.

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