By: WISCONSIN LAW JOURNAL STAFF//December 26, 2023//
7th Circuit Court of Appeals
Case Name: Chris Martin v. Kilolo Kijakazi
Case No.: 22-1972
Officials: Hamilton, Brennan, and Jackson-Akiwumi, Circuit Judges.
Focus: Social Security Disability
Chris Martin experienced a back injury in June 2016 prompting him to cease working. Seeking medical attention in February 2018, he was diagnosed with a spine disorder in May 2018. Applying for Social Security disability benefits, Martin was granted supplemental security income after an administrative law judge (ALJ) determined him disabled according to the Social Security Act’s rigorous definition. However, his request for disability insurance benefits was denied because his insured status for those benefits had expired on December 31, 2017, a few weeks before the determination of his disability.
In his appeal, Martin contended that the ALJ should have consulted an additional medical expert to ascertain whether he was disabled before the expiration of his insured status. The Seventh Circuit concluded that the ALJ did not abuse her discretion in opting not to seek another medical expert’s opinion. The court clarified that Social Security Ruling 18–01p empowers an ALJ to make the decision on whether to consult an additional medical expert to address that specific question. Consequently, the court upheld the denial of disability insurance benefits.
Affirmed.
Decided 12/19/23