Hill v. Colvin

Federal 7th Circuit Court
Civil Court
Social Security
Citation
Case Number: 
No. 15-1230
Decision Date: 
December 3, 2015
Federal District: 
N.D. Ind., Ft. Wayne Div.
Holding: 
Reversed and remanded

Record failed to support ALJ’s denial of claimant’s application for Social Security disability benefits, even though ALJ found that claimant was unbelievable in her claim that she could not sit, stand or walk for extended periods of time because of injuries to her hip, shoulder and back. Instant negative credibility findings were based on flawed reasoning that claimant had stopped taking narcotic pain relievers and had failed to seek back specialist, where innocent explanations existed for claimant’s actions. Moreover, ALJ’s observation that claimant’s pain complaints were exaggerated because claimant had not been diagnosed with nerve root compression was not supported by medical evidence, and ALJ could not base any negative credibility finding on claimant’s testimony that she still wanted to work and had worked in manual labor jobs for many years. Also, Commissioner could not rely on evidence that claimant could perform daily living tasks to support ALJ’s decision that claimant could perform certain light duty jobs, where: (1) ALJ did not base denial of claimant's application on said fact; and (2) performance of daily activities does not necessarily support finding that claimant could perform full-time job.