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Spicher v. Berryhill

898 F.3d 754 (2018)

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Spicher v. Berryhill

United States Court of Appeals for the Seventh Circuit

898 F.3d 754 (2018)

Facts

Susan Spicher (plaintiff) suffered from osteoarthritis, degenerative disc disease, chronic obstructive pulmonary disease, fibromyalgia, and obesity. Spicher applied for disability benefits from the Social Security Administration (SSA) (defendant). The administrative-law judge determined that Spicher was disabled as of 2012, when Spicher turned 50 years old. Spicher appealed, and the district court remanded the case to the administrative-law judge to correctly consider the effects of Spicher’s obesity and consider an earlier disability onset date. The administrative-law judge affirmed her initial determination. In making her decision, the administrative-law judge did not consider the interaction between Spicher’s obesity and her other impairments and did not consider evidence from Spicher’s doctor regarding Spicher’s physical limitations. At the redetermination hearing, the administrative-law judge made comments about the district court disagreeing with her initial decision. The administrative-law judge also stated that she wanted to work out whether the medical evidence supported her initial determination. When Spicher refused to amend her request for an earlier onset date, the administrative-law judge asked whether she wanted to go to federal court again. Spicher appealed, arguing the administrative-law judge improperly concluded that Spicher was not disabled as of an earlier date and violated Spicher’s due-process rights by prejudicing the outcome of the case.

Rule of Law

Issue

Holding and Reasoning (Kanne, J.)

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