Judge Posner, writing for the United States Court of Appeals for the Seventh Circuit, ruled in favor of the plaintiff claiming Social Security benefits for her disability in Goins v. Colvin, No. 13-3729. Krystal Goins, the plaintiff, filed for Supplemental Security Income and was denied by the Social Security's administrative law judge. The ALJ concluded that the plaintiff was not a credible witness and that medical evidence did not support her claim of suffering from acute pain related to a herniated spinal disc. She appealed this denial to the federal district court, where the denial was affirmed. Plaintiff then appealed to the 7th Circuit Court of Appeals.
The lower courts based their decision on the lack of medical records between 1998, when an MRI first revealed the herniated disc, and 2007. It is a common argument that when an injured person does not seek continual medical treatment, they are not as severely injured as they claim and should not receive the benefits requested, whether they are social security benefits or worker's compensation benefits. Physicians used by the state agency in this case that was assisting the Social Security Administration concluded, based merely on reviewing medical records and/or interviewing the Plaintiff, that there was insufficient medical evidence to support the Plaintiff's claims of pain and inability to work. However, they failed to point to specific medical records or evidence that supported their conclusions. Judge Posner stated in his ruling that the reasons the ALJ gave for finding that Plaintiff exaggerated her pain were unsound. Judge Posner set out the following conclusions, important to any disability case:
1) The fact that someone works is not sufficient grounds for concluding that he or she is not disabled; many people continue to work out of necessity even through pain and conditions that would enable them to receive benefits.
2) The fact that a claimant does not seek frequent medical treatment cannot be used against them to prove that their condition is not severe; people seeking social security benefits are generally low-income and cannot afford medical treatment and/or do not have health insurance. Even treatment at low-income facilities require payment from patients.
3) The consulting physicians for the state agency did not have sufficient medical evidence to give their conclusions that Plaintiff was not disabled; they did not examine the Plaintiff and were vague about what medical evidence actually did support their conclusions.
In addition, the ALJ failed to consider a recent MRI from 2010 showing worsening disc disease. The physicians also did not have this MRI to consult and could not therefore make an accurate conclusion as to Plaintiff's condition. The ALJ and physicians did not believe Plaintiff to be credible, for no apparent reason, other than that a functional capacity evaluation showed she can perform some work while she testified that she cannot. The ALJ therefore disregarded Plaintiff's testimony as not credible and ruled based on a belief that she was lying about her pain and ability to work.
Judge Posner made a very pointed statement with this ruling, sending a message to agencies and administrative law judges, as well others involved in disability benefits lawsuits, that a claimant's testimony should be given great deference and not thrown out based on the biased belief that disability claimants are exaggerating their claims.