Abuse of Discretion – Disability Benefits

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7^th Circuit Court of Appeals

Case Name: Melissa Vanprooyen v. Nancy A. Berryhill

Case No.: 16-3653

Officials: POSNER, KANNE, and SYKES, Circuit Judges.

Focus: Abuse of Discretion – Disability Benefits

Vanprooyen points to the administrative law judge’s flawed credibility assessments of her and her fiancé and disregard for the opinions of her treating physicians, and notes that in finding her not credible the administrative law judge had overemphasized her daily activities—and equating daily activities with an ability to work can lead to reversal. See Bjornson v. Astrue, 671 F.3d 640, 647 (7th Cir. 2012). Of particular significance, Vanprooyen points out that the administrative law judge misunderstood the significance of her employment before her onset date (that is, the date several months after her fall down the stairs when her disability compelled her to quit work).

Vanprooyen further contends that the administrative law judge improperly discounted the opinions of treating sources in rejecting the views of her personal physician, neurologist, and psychiatrist. We agree with Vanprooyen that the administrative law gave no logical reason for discounting the opinions of these doctors, such as Dr. Jones. Because of the serious deficiencies in the administrative law judge’s analysis, we reverse the decision of the district court and remand the case to the Social Security Administration for further proceedings consistent with this opinion.

Reversed and Remanded

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Attorney Derek A. Hawkins is the managing partner at Hawkins Law Offices LLC, where he heads up the firm’s startup law practice. He specializes in business formation, corporate governance, intellectual property protection, private equity and venture capital funding and mergers & acquisitions. Check out the website at www.hawkins-lawoffices.com or contact them at 262-737-8825.