## Facts

- James Young, a 55-year-old military veteran, suffered a traumatic brain injury in a 1987 motorcycle accident, followed by a prolonged coma and lasting cognitive and personality changes.
- After being discharged from the Air Force as disabled in 1990, he worked various jobs but repeatedly could not maintain employment.
- The Department of Veterans Affairs rated him 70% disabled and “100 percent unemployable.”
- Young applied for Social Security disability insurance benefits in 1998, alleging disability since 1992 due to mental impairments tied to the brain injury.
- An ALJ found Young not disabled, concluding he could do simple, routine, repetitive, low-stress work with limited contact with others and that jobs existed in significant numbers.
- The ALJ considered records and opinions from multiple psychological and medical professionals but gave reduced weight to the most recent agency-retained examining physician.
- The Appeals Council denied review, and the district court affirmed the denial of benefits.

## Issues

1. Whether the ALJ’s residual functional capacity (RFC) determination accounted for all mental limitations supported by the record.
2. Whether the ALJ’s hypothetical question to the vocational expert (VE) included all supported limitations such that the VE’s testimony could constitute substantial evidence at step five.
3. Whether the ALJ adequately explained the weighing and discounting of examining medical opinion evidence, including the last examining physician’s assessment.

## Decision

- The Seventh Circuit reversed the district court’s judgment affirming the denial of benefits.
- The court remanded to the Commissioner for further proceedings.
- The court held that the ALJ’s RFC assessment and related VE hypothetical were flawed and therefore the step-five denial was not supported by substantial evidence.

## Legal Principles

- Judicial review of a Social Security disability decision asks whether the ALJ’s findings are supported by substantial evidence; courts do not reweigh evidence, resolve record conflicts, or make credibility determinations.
- RFC must be based on all relevant record evidence, and the ALJ must articulate a reasoned explanation connecting evidence to specific functional limitations.
- An ALJ may weigh competing medical opinions, but discounting an examining source requires specific, record-based reasons; speculation about a claimant’s incentives in a disability examination is insufficient by itself.
- VE testimony can constitute substantial evidence at step five only if the hypothetical question includes all limitations supported by medical evidence; omissions of supported mental limitations invalidate reliance on the VE’s response.

## Conclusion

The court remanded because the ALJ did not adequately account for record-supported cognitive and personality limitations in the RFC and VE hypothetical and did not sufficiently justify discounting the most recent examining physician, leaving the denial unsupported by substantial evidence.


Young v. Barnhart, 362 F.3d 995 (7th Cir. 2004)