Moore v. Colvin

Moore applied for Social Security disability benefits, alleging that she became disabled in 2007. An ALJ concluded that Moore suffered from a number of severe impairments, including migraine headaches, asthma, morbid obesity, and rheumatoid arthritis, and less severe impairments including irritable bowel syndrome, gastroesophageal reflux disease, hypertension, hypothyroid and prolactin irregularities, carpal tunnel syndrome, depression, anxiety, and possible Crohn’s disease. The ALJ found that she was, nonetheless, capable of performing her past work and not entitled to benefits. The district court affirmed. The Seventh Circuit reversed and remanded. The ALJ did not err in considering evidence that Moore’s emergency room visits may have been related to an addiction problem, but the ALJ erred in failing to even acknowledge contrary evidence or to explain the rationale for crediting the identified evidence over contrary evidence. The ALJ never related Moore’s specific limitations to certain impairments. On remand, the ALJ must make those findings and present the limitations to the vocational expert to determine whether Moore is capable of performing her past relevant work. View "Moore v. Colvin" on Justia Law