## Facts

- Patty Carradine applied for Social Security disability benefits, alleging disabling chronic back and related pain.
- She had a serious back injury and received prolonged medical care from multiple physicians.
- Diagnoses included scoliosis, depression, and psychosomatic illness (physical distress with a psychological origin).
- Her treatment included strong pain medications and spine surgery undertaken in an attempt to relieve pain.
- An Administrative Law Judge (ALJ) found Carradine had a “severe impairment” but denied benefits after rejecting her testimony about the severity and functional effects of her pain.
- The ALJ reasoned that psychosomatic illness made her more likely to exaggerate; physicians lacked objective findings supporting the alleged pain level; and reported activities (household chores and two-mile walks) were inconsistent with disabling pain.
- The Appeals Council denied review; the district court affirmed the Commissioner’s decision; Carradine appealed.

## Issues

1. Whether the ALJ’s credibility determination rejecting Carradine’s subjective pain testimony was supported by substantial evidence and applied proper standards for evaluating pain.
2. Whether the ALJ properly accounted for the medical record and treatment history, including surgery and strong medication, in concluding her pain was not disabling.

## Decision

- The Seventh Circuit reversed the district court’s judgment affirming the denial of benefits and remanded for further proceedings.
- The court held the ALJ’s credibility analysis was not supported by substantial evidence and reflected legal error in evaluating subjective pain, including pain with psychological components.
- The court rejected the ALJ’s inference that a psychosomatic diagnosis implies exaggeration rather than potentially disabling pain.
- The court found the ALJ’s reliance on limited daily activities to disprove disability was not a valid basis for concluding Carradine could sustain full-time work.
- The court treated the intensity and invasiveness of Carradine’s treatment (including surgery and strong medication) as significant corroboration of her pain complaints that the ALJ did not reasonably address.

## Legal Principles

- A claimant’s pain may be severe and disabling even when objective medical findings are limited.
- Once a claimant shows a medically determinable impairment that could cause pain, subjective symptom testimony may not be discredited solely due to lack of objective corroboration.
- Pain with psychological or psychosomatic origins can be real and debilitating and must be evaluated as part of the disability analysis, not treated as evidence of fabrication.
- Treatment history, including invasive procedures and strong medication, is relevant evidence bearing on symptom severity and credibility.
- Minimal or sporadic daily activities do not, without more, establish capacity to perform sustained full-time work.
- Credibility determinations require a coherent, evidence-based explanation consistent with the record as a whole.

## Conclusion

The Seventh Circuit required reconsideration of Carradine’s disability claim because the ALJ improperly discounted her pain allegations by mischaracterizing psychosomatic pain, minimizing corroborative treatment evidence, and overstating the significance of limited daily activities.


Carradine v. Barnhart, 360 F.3d 751 (7th Cir. 2004)