Garcia v. Colvin

Michael Garcia (plaintiff) had several psychological and physical issues, including severe abdominal pain from liver and hernia problems, lupus, anemia, chronic fatigue, and alcoholism. Garcia was a construction worker. Although Garcia frequently took days off each week due to his medical issues, his employer kept him working full-time because the employer valued Garcia’s specialized skills. However, Garcia’s employer then went out of business. Around that time, Garcia stopped consuming alcohol, but his pain and other issues continued to worsen. Garcia occasionally helped a friend build a house and babysat an older child for free, but he was unable to obtain paying work even part-time. Garcia had no health insurance and did not seek medical care for over a year. Eventually, at age 40, Garcia applied for Social Security disability benefits. All the doctors who examined Garcia agreed that Garcia was capable of standing, sitting, and walking but that his extensive physical and mental impairments meant that he was (1) housebound, (2) unable to consistently perform even basic household chores, (3) likely terminal, and (4) clearly unable to engage in substantial gainful activity. A vocational expert testified that missing even one day of work per month would make it hard for a person to obtain gainful, full-time employment and that it was highly unlikely that Garcia could get or keep a full-time job. The administrative-law judge assigned to Garcia’s application ruled that (1) the doctors’ and expert’s opinions were irrelevant; (2) because Garcia did not seek medical treatment for a year, he must be exaggerating his pain levels; and (3) because Garcia could stand, walk, and help a friend build a house occasionally, he could perform paid work on a full-time basis. The judge denied Garcia’s application, and a federal district court affirmed the denial. Garcia appealed to the Seventh Circuit.