Durham v. Kijakazi, No. 21-3235 (7th Cir. 2022)Annotate this Case
In 2017 Durham, age 46, applied for Social Security disability benefits, she had been diagnosed with diabetes and hypertension. She had also seen medical professionals about neck pain and heart palpitations. She had been experiencing shortness of breath and lightheadedness and was referred to a cardiologist, who counseled her to reduce her caffeine intake and to adopt a healthy lifestyle. Durham continued to have intermittent symptoms and, in 2019, was admitted to a hospital due to “exertional shortness of breath and palpitations.” Testing disclosed that Durham had no cardiac instability, “no acute problems, [and] no functional limitations.”
An Administrative Law Judge concluded that Durham’s diabetes, hypertension, and tachycardia were limiting, but not disabling, conditions. The district court and Seventh Circuit upheld the denial of benefits as supported by substantial evidence. The court rejected arguments that the ALJ relied on outdated evidence and overstepped his authority by interpreting, without supporting medical opinions, the results of medical tests. The record reveals that the ALJ carefully considered Durham’s entire medical history and relied on the opinions of her treating physicians in reaching his conclusions about her physical limitations.