Public Health — disability benefits

U.S. Court of Appeals for the Seventh Circuit

Civil

Public Health — disability benefits

Where the ALJ failed to consider a disability claimant’s conditions collectively, the denial of benefits must be reversed.

“We cannot find that these errors were harmless. It seems to us that taking all of Thomas’s impairments together would result in a more restricted RFC than the ALJ formulated. And the ability to use her left hand was integral to Thomas’s past work as a phlebotomist, and thus her claim. As the VE testified, if Thomas were limited to ‘occasional grasping’ with her left, non-dominant hand, she could not work as a phlebotomist, even at a light exertional level. If Thomas could not do her past work, she would have been considered disabled and thus eligible for benefits. 20 C.F.R. app. 2 § 404(p) (a person over age fifty-five who lacks transferable skills and cannot do previous relevant work is considered disabled).”

Reversed and Remanded.

13-2602 Thomas v. Colvin

Appeal from the United States District Court for the Northern District of Illinois, Finnegan, Mag. J., Kanne, J.