U.S. Court of Appeals for the 7th Circuit
Public Health — disability benefits
Where the ALJ failed to build a logical bridge between substantial evidence and his conclusion that a disability claimant with migraines was capable of a limited range of sedentary work, the denial of benefits is reversed.
“Apart from Chenery concerns, the doctors’ opinions cannot provide the needed logical bridge. Dr. Kim did not actually specify how Moon’s migraines relate to the residual functional capacity she found. She did not address the possibility that a migraine could keep Moon at home in bed, apparently understanding Moon’s ‘history of frequent migraines’ to have implications only for her ability to lift, stoop, and stand. Dr. Francis’s report provides even less support for the government’s position. He noted: ‘There is not enough information [in the medical records] on the frequency of [Moon’s] migraines to determine how much these contribute to her overall impairment.’ Unlike Dr. Kim and Dr. Francis (who, remember, never even met Moon), the ALJ had the opportunity to hear Moon’s own account about how her migraines limit her activities, and as explained above, his apparent disbelief of her testimony is not justified in his decision.”
Reversed and Remanded.
Appeal from the United States District Court for the Northern District of Illinois, Cox, Mag. J., Hamilton, J.