Vanprooyen v. Berryhill, No. 16-3653 (7th Cir. 2017)Annotate this Case
By 2009 Vanprooyen’s physician had prescribed Xanax to treat her panic attacks. She was treated for anxiety, depression, and bipolar disorder. She had a history of addiction. In 2010, Vanprooyen, then age 26, fell down a flight of stairs and suffered a brain hemorrhage. She claimed post-traumatic stress disorder, short-term memory loss, attention-deficit hyperactivity disorder, seizures, and fibromyalgia. She was prescribed medication for pain, migraine headaches, and seizures. Vanprooyen applied for Disability Insurance Benefits and Supplemental Security Income. An administrative law judge found her impairments to be severe but not disabling and denied benefits. The district court upheld the ALJ’s decision. The Seventh Circuit reversed, finding “serious deficiencies” in the ALJ’s analysis, which failed to mention that a state consultative examiner who had given Vanprooyen a mental-status examination concluded that she was unable to manage her own money because of her “emotional adjustment and medical difficulties,” although at least two of the three jobs that the ALJ found that Vanprooyen could do involve handling money. Without explanation, the ALJ gave substantial weight to the opinions of consulting physicians who had never examined Vanprooyen. An ALJ can reject an examining physician’s opinion only for reasons supported by substantial evidence; a contradictory opinion of a non-examining physician does not, alonef, suffice.