Social Security Disability Benefits-Burden of Proof

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7^th Circuit Court of Appeals

Case Name: Morgan Morales v. Martin O’Malley

Case No.: 23-2796

Officials: Easterbrook, Scudder, and Kirsch, Circuit Judges.

Focus: Social Security Disability Benefits-Burden of Proof

Morales appealed an administrative law judge’s (ALJ) ruling that she wasn’t disabled and thus ineligible for Social Security disability benefits. Morales asserted she suffered from various conditions, including bipolar disorder, depression, anxiety, ADHD, and narcolepsy. Despite treatment at a mental health center and medication, Morales claimed her conditions were in remission. However, the ALJ denied her benefits application, determining her mental impairments were mild and didn’t hinder her ability to perform basic work activities, including her previous role as a material handler.

Morales disputed the ALJ’s decision in the Southern District of Indiana. She argued the ALJ misjudged her ability to work but failed to provide compelling evidence challenging the substantial support for the denial of disability benefits. The District Court upheld the ALJ’s ruling, stating Morales hadn’t met her burden of proof and that substantial evidence backed the decision.

The Seventh Circuit noted Morales misunderstood her burden of proof on appeal—it wasn’t sufficient to merely criticize the ALJ’s decision; she needed evidence compelling the conclusion that the denial lacked substantial support in the record. Additionally, the court dismissed Morales’s critique of the District Court’s ruling, affirming its thorough review of the ALJ’s determination and proper application of the law. Ultimately, the court concluded the ALJ’s decision was reasonable and supported by substantial evidence.

Affirmed.

Decided 05/31/24

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