By: WISCONSIN LAW JOURNAL STAFF//July 17, 2023//
7th Circuit Court of Appeals
Case Name: Angela Crowell v. Kilolo Kijakazi
Case No.: 22-3097
Officials: Easterbrook, Rovner, and Lee, Circuit Judges
Focus: Supplemental Social Security Insurance Benefits
In 2010, Crowell applied for Supplemental Social Security Insurance benefits, stating that she was unable to work due to various health conditions, including ADHD, social anxiety, fibromyalgia, bipolar disorder, borderline personality disorder, chronic pain, panic attacks, arthritis, shoulder pain, back pain, OCD, anxiety, depression, insomnia, asthma, and COPD. The Administrative Law Judge (ALJ) acknowledged that certain impairments met the severity criteria outlined in the regulations, specifically fibromyalgia, depressive disorder, anxiety disorder, and shoulder impairments that persisted after surgery. The ALJ also considered Crowell’s claims related to asthma, back problems, substance abuse, and “absence” spells but determined that they did not meet the criteria for severe impairments. Consequently, the Social Security Administration denied her application.
Following several appeals and remands, the district court upheld the denial of benefits, a decision that was subsequently affirmed by the Seventh Circuit. Throughout the evaluation process, the ALJ appropriately followed the five-step procedure for determining disability, as outlined in 20 C.F.R. 416.920. This involved assessing whether the claimant was currently employed, had severe impairments or a combination thereof, possessed impairments that met or equaled the severity of listed impairments preventing substantial gainful activity, had residual functional capacity that rendered her unable to perform past relevant work, and was unable to perform other work available in significant numbers within the national economy.
Affirmed.
Decided 07/07/23