Meuser v. Colvin

Federal 7th Circuit Court
Civil Court
Social Security
Citation
Case Number: 
No. 16-1052
Decision Date: 
October 3, 2016
Federal District: 
S.D. Ind., Evansville, Div.
Holding: 
Reversed and remanded

Record failed to contain sufficient evidence to support ALJ’s denial of claimant’s application for Social Security disability benefits, where said denial was based on ALJ’s assessment at Step 2 of 5-step disability analysis that claimant’s schizophrenia diagnosis was not severe impediment. Diagnosis of schizophrenia, standing alone, is sufficient to satisfy severe impairment requirement at Step 2, and ALJ improperly conflated Steps 2,4 and 5 in denying instant application. Moreover, ALJ fundamentally misunderstood claimant’s symptoms of schizophrenia, which led him to mistakenly conclude that claimant’s mental condition was “essentially normal.” ALJ also improperly rejected opinion of claimant’s treating physician and improperly ignored evidence that claimant needed help to accomplish activities in daily living.