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Nelson v. Apfel
210 F.3d 799 (7th Cir. Apr. 27, 2000) ; Clearinghouse Number: 53056
Description
Remand for Clarification of the Record in Disability Determination Is Proper When Experts’ Testimony Conflicts
Abstract
The Seventh Circuit held that the district court did not abuse its
discretion by remanding this case to the administrative law judge
to resolve factual conflicts in the record. Based on heart disease,
leg pains, shortness of breath, and depression, plaintiff applied
for social security disability and Supplemental Security Income
benefits. Her application was denied, and the administrative law
judge concluded that she was not disabled. The district court found
a conflict between the testimony of the psychiatrist and the
vocational expert and remanded the case. Appealing that decision,
plaintiff argued that the record supported only a finding of
disability. The Seventh Circuit held that the district court did
not abuse its discretion in finding that the psychiatrist’s
and vocational expert’s testimony supported both the
conclusion that plaintiff suffered and the conclusion that she did
not suffer from a severe impairment. The psychiatrist testified
that plaintiff’s depression was not severe because it did not
affect her ability to work but also rated her degree of functional
loss as “often” in the area of concentration,
persistence, or pace. That, according to the vocational expert,
would preclude plaintiff from substantial gainful activity and thus
qualify her depression as a severe impairment. The Seventh Circuit
concluded that the psychiatrist’s meaning of
“often” conflicted with that of the vocational expert.
