## Facts

- Michael E. Garcia, a former construction worker in his early forties, applied for Social Security disability benefits in 2010, alleging disability since 2008.
- He alleged disabling abdominal pain and related limitations from cirrhosis of the liver, severe thrombocytopenia, hepatitis C, and an umbilical hernia, along with additional conditions including lupus, anemia, colitis, anxiety and other psychological problems, and chronic fatigue.
- Physicians documented extreme severity: repeated hospitalizations for abdominal pain; treatment with morphine and other opioids with limited relief; liver-transplant candidacy complicated by being deemed too sick for surgery; and a platelet count too low to safely undergo a liver biopsy.
- One physician characterized his condition as chronic and terminal and described Garcia as disabled due to pain and fatigue.
- Garcia stopped drinking in 2010; the record did not show ongoing alcoholism as a material contributing factor to disability.
- Because he lacked health insurance, Garcia went more than a year without seeking medical care.
- Garcia reported only sporadic, unpaid activities (e.g., occasional assistance on a house project and babysitting), not sustained paid employment.
- Two examining physicians, including one tied to the state disability agency process, concluded Garcia could not engage in substantial gainful activity.
- A vocational expert testified that missing even one day of work per month would seriously impair employability and that it was highly unlikely Garcia could obtain or keep full-time work given his limitations.
- An ALJ found Garcia capable of sedentary work with limitations and denied benefits; the district court affirmed.

## Issues

1. Whether substantial evidence supported the ALJ’s residual functional capacity finding that Garcia could perform sedentary work.
2. Whether the ALJ properly evaluated Garcia’s symptom allegations, including reliance on a treatment gap and limited daily activities.
3. Whether the ALJ improperly discounted consistent medical opinions and vocational expert testimony bearing on employability and absenteeism.

## Decision

- The Seventh Circuit reversed the district court’s judgment affirming the Commissioner’s denial of benefits.
- The court held the ALJ’s sedentary-work finding was not supported by substantial evidence in light of the medical record and vocational testimony.
- The court found the ALJ improperly relied on a gap in treatment without accounting for lack of insurance and improperly treated sporadic activities as evidence of full-time work capacity.
- The case was remanded with directions consistent with recognizing disability, in light of the overwhelming evidence.

## Legal Principles

- Judicial review requires that an ALJ’s disability determination be supported by substantial evidence and explained with reasoned analysis grounded in the record.
- An ALJ may not draw adverse inferences from a claimant’s failure to obtain treatment without considering inability to pay or lack of insurance.
- Minimal, sporadic daily activities and occasional informal tasks are weak evidence of capacity to sustain full-time competitive employment.
- An ALJ must give coherent reasons for rejecting consistent medical assessments, including opinions obtained through the agency’s own evaluation process.
- Vocational expert testimony about the effect of absenteeism and functional limitations on competitive employment must be meaningfully addressed in the disability analysis.
- Alcoholism bars benefits only if it is a contributing factor material to the disability determination; cessation and lack of evidence of material contribution cannot be ignored.

## Conclusion

The Seventh Circuit reversed because the ALJ’s denial rested on unsupported conclusions and flawed reasoning: the record described severe, well-documented impairments inconsistent with sustained sedentary work, and the ALJ improperly discounted medical and vocational evidence while relying on a treatment gap and sporadic activities that did not show full-time work ability.


Garcia v. Colvin, 741 F.3d 758 (7th Cir. 2013)