MARTINEZ v. ASTRUE (January 19, 2011)
Anita Martinez and her five children live in her mother's basement. Martinez suffers from depression, bipolar disorder, and severe arthritis. She is on medication for both her mental and physical complaints. An ALJ denied her claim for disability benefits. Francis Rider is 61 years old, extremely obese, has severe arthritis in her right knee, and suffers from back pain. An ALJ denied her request for disability benefits. Christine Pound is 60 years old and suffers from coronary artery disease, cartoid artery disease, back pain, and restless leg syndrome. But Pound only had Social Security coverage through the end of 2003. At that time, her conditions were under control and she used only mild medication to treat her pain. An ALJ denied her request for disability benefits. Martinez, Rider, and Pound appeal.
In their opinion, Judges Posner, Ripple, and Rovner consolidated the three appeals and reversed and remanded in Martinez and Rider and affirmed in Pound. In these consolidated appeals, the Court again (as in Spiva (opinion and intheiropinion) and Parker (opinion), both opinions also written by Judge Posner) took the opportunity to criticize the Social Security Administration and its handling of benefit claims. It specifically disapproved of the common ALJ practice of concluding a claimant's statements are not credible without explanation and also noted many ALJs’ apparent lack of familiarity with mental illness. On the merits of the appeals, the Court: a) reversed and remanded the benefits denial in Martinez because the ALJ's superficial opinion discounted Martinez' testimony as "not entirely credible" without explanation, ignored much of the evidence, overlooked the fact that she stopped taking her medication at times because of her condition, and never considered the cumulative impact of her various problems, b) reversed and remanded the benefits denial in Rider because the ALJ ignored the treating doctor's opinion that she was not capable of prolonged standing or walking, relied on contrary opinions of non-treating physicians, made findings inconsistent with the evidence, ignored the uncontroverted testimony that Rider could not afford a knee replacement, and failed to consider the impact of her obesity on her physical condition, and c) affirmed the benefits denial in Pound because, although her condition deteriorated rapidly after 2004, the ALJ conducted a thorough analysis and denied benefits in a thorough opinion that concluded that Pound could perform sedentary work (and was therefore not disabled) when her coverage expired.