Reynolds v. Kijakazi, No. 21-1624 (7th Cir. 2022)
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Reynolds, born in 1992, graduated from high school and previously worked part-time in retail. Reynolds suffers from migraines, vertigo, and “major depressive disorder, recurrent moderate with anxious distress.” She applied for Social Security disability benefits in 2017. Reynolds testified that she suffers from back pain, vertigo, and migraines, and she cannot stand for more than 10 minutes. Her parents handle household chores. She has migraines every day. She stopped taking some prescription medications for her migraines because of the side effects. Reynolds quit her job at Walmart because of her migraines. Reynolds testified has never gone to an emergency room or crisis center for mental health treatment but suffers from anxiety around “more than five people.” She was taking medication for her mental health conditions.
The ALJ concluded that Reynolds was not disabled under the Social Security Administration’s five-step method and that Reynolds had the residual functional capacity to perform a full range of work with certain non-exertional limitations. The Seventh Circuit affirmed the denial as supported by substantial evidence. The court rejected an argument that the ALJ erred by failing to include a qualitative interaction limitation in the residual functional capacity determination. No medical evidence called for a qualitative interaction limitation; the ALJ was not required to intuit such a limitation from the administrative record.
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