Crowell v. Kijakazi, No. 22-3097 (7th Cir. 2023)
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Crowell sought Supplemental Social Security Insurance benefits in 2010, alleging that she was unable to work due to ADHD, social anxiety, fibromyalgia, bipolar disorder, borderline personality disorder, chronic pain, panic attacks, arthritis, shoulder pain, back pain, OCD, anxiety, depression, insomnia, asthma, and COPD. The ALJ agreed that certain impairments were severe as defined under the regulations: fibromyalgia, depressive disorder, anxiety disorder, and impairments of her left shoulder which remained after surgical correction, and also considered Crowell’s claims that she suffered from asthma, back problems, substance abuse, and “absence” spells, but deemed that none of those conditions met the criteria of severe impairments. The Social Security Administration denied her application.
After several appeals and remands, the district court upheld the denial of benefits. The Seventh Circuit affirmed. The ALJ appropriately followed the five-step process for evaluating whether a plaintiff is disabled, 20 C.F.R. 416.920, considering whether the claimant is currently employed, has a severe impairment or combination of impairments, has an impairment that meets or equals any impairment listed as being so severe as to preclude substantial gainful activity, has residual functional capacity that leaves her unable to perform past relevant work, and is unable to perform any other work existing in significant numbers in the national economy.
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