White v. Social Security Administration, Commissioner

Ronald White applied for Disability Insurance Benefits, claiming severe back and knee impairments. An administrative law judge denied his claim after giving little weight to his treating physician's opinion regarding his functional limitations, finding White capable of sedentary work. The district court affirmed the denial. On appeal to the Seventh Circuit, White argued the ALJ improperly evaluated the medical evidence and failed to provide good reasons for discounting the treating physician's assessment. The appellate panel examined the record and concluded that the ALJ's reasoning was flawed. The court emphasized that under the treating physician rule, a doctor's longitudinal view of the patient deserves deference, and the ALJ substituted her own lay judgment for expert medical opinion. The case was reversed and remanded for further proceedings, highlighting the necessity for ALJs to articulate specific, legitimate reasons supported by substantial evidence when rejecting treating source opinions.

The United States Court of Appeals for the Seventh Circuit reversed the district court's judgment and remanded with instructions to return the case to the Social Security Administration for further proceedings consistent with the opinion.

Whether the administrative law judge erred by improperly weighing the medical opinion evidence, particularly by giving little weight to the treating physician’s assessment without providing sufficient good reasons grounded in substantial evidence.

The decision reinforced the strict application of the treating physician rule within the Seventh Circuit, reminding adjudicators that they must not play doctor. It provided clearer guidance on evaluating medical opinions in social security disability cases and underscored the rights of claimants to have their long-term treating source records fairly considered, influencing subsequent administrative and judicial reviews.