Please ensure Javascript is enabled for purposes of website accessibility
Home / Case Digests / Public Health — disability benefits

Public Health — disability benefits

United States Court of Appeals For the Seventh Circuit


Public Health — disability benefits

Where the ALJ never related a disability applicant’s migraines to her capacity to maintain employment, the denial of benefits is reversed.

“In conclusion, significant medical and testimonial evidence independent of the questionable emergency room visits established a history of severe recurrent migraines. In light of that evidence, the ALJ erred in disregarding the migraines as a factor in determining Moore’s ability to perform her past work. Specifically, the ALJ should have at least included in the RFC determination the likelihood of missing work. The ALJ’s decision did not reflect any likelihood of absences or breaks at work related to migraines, and that is simply unsupported by the record. As to the limitations imposed by that severe impairment, the ALJ recognized in the RFC only that she should be limited to sedentary work in which she could avoid concentrated exposure to extreme cold, extreme heat, noise, fumes, odors, dusts, gases, poor ventilation, hazardous machinery and heights. The ALJ never related those specific limitations to certain impairments. It is possible to postulate which were related to migraines as opposed to the other severe or non-severe impairments such as obesity, asthma and rheumatoid arthritis, but the reviewing court should not have to speculate as to the basis for the RFC limitations. Nor is the basis otherwise apparent in the record. Accordingly, the case must be remanded for the ALJ to articulate with clarity the limitations related to the impairments based on an examination of the evidence in the record as a whole, and to present those limitations to the vocational expert to determine whether Moore is capable of performing her past relevant work.”

Reversed and Remanded.

13-2460 Moore v. Colvin

Appeal from the United States District Court for the Northern District of Illinois, Cox, Mag. J., Rovner, J.

Leave a Reply

Your email address will not be published. Required fields are marked *