Emily Watts, on behalf of Kenny Watts, Deceased v. FRANK BISIGNANO, Commissioner of Social Security

United States Court of Appeals
For the Seventh Circuit
Chicago, Illinois 60604
Argued September 3, 2025
Decided September 24, 2025
Before
MICHAEL Y. SCUDDER, Circuit Judge
THOMAS L. KIRSCH II, Circuit Judge
DORIS L. PRYOR, Circuit Judge
No. 24-3044
EMILY WATTS, on behalf of Kenny
Watts, Deceased,
Plaintiff-Appellant,
v.
FRANK BISIGNANO, Commissioner of
Social Security,
Defendant-Appellee.
Appeal from the United States District
Court for the Central District of Illinois.
No. 2:23-cv-02139-CSB-EIL
Colin S. Bruce,
Judge.
O R D E R
Kenny Watts first applied for disability benefits over a decade ago, and the record of
his medical conditions is extensive. He obtained partial success in 2020, when an
administrative law judge found that he became disabled—but only as of December 21,
2018. This appeal follows a hearing before another ALJ, who reviewed the evidence and
agreed that Watts was not disabled prior to that date. Emily Watts now challenges this
determination on behalf of her late husband. While sympathetic to Watts’s suffering, we
NONPRECEDENTIAL DISPOSITION
To be cited only in accordance with Fed. R. App. P. 32.1

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conclude that the record contains substantial evidence supporting the ALJ’s decision. So
we affirm.
I
A
Kenny Watts applied for disability insurance benefits and supplemental security
income in September 2010. He alleged an onset of disability of June 1, 2008. Watts’s
application has resulted in five evidentiary hearings before ALJs, with the earliest in 2012
and the most recent in 2023.
Watts’s initial application focused on physical conditions, alleging carpal tunnel
syndrome and a shoulder injury. Naturally, however, Watts’s medical evidence has
changed during the lengthy pendency of his application. The most recent medical record
shows a series of mental and physical impairments.
Two developments in the medical evidence are most relevant to this appeal. First, on
December 21, 2018, Dr. Catherine York conducted a neuropsychological evaluation of
Watts and found vascular dementia. Second, in October 2020, after Watts’s fourth hearing,
ALJ Deborah Ellis requested expert review of Watts’s medical records. In response, Dr.
Lauren Frey, a neurologist, completed a form and medical interrogatories supplied by
the Social Security Administration.
When asked to identify Watts’s impairments, Dr. Frey specified right median
neuropathy, lumbar stenosis, and vascular dementia. She found that Watts did not meet
or medically match the Administration’s listings of impairments—which would qualify
him as disabled—based on either of the first two conditions. But Dr. Frey did conclude
that, as of December 21, 2018, Watts’s vascular dementia met listing 12.02, which applies
to neurocognitive disorders. For the period of June 1, 2008 through December 21, 2018,
Dr. Frey identified several limitations on Watts’s ability to do work-related activities. She
did not conclude that Watts was disabled during this earlier period, however.
In November 2020 ALJ Ellis issued an order finding that Watts became disabled as of
December 21, 2018. This decision awarded Watts supplemental security income but left
him ineligible for disability insurance benefits because his date last insured was March
31, 2015—before the December 2018 disability date. Watts appealed to district court, and
the court granted the Commissioner’s motion to remand.
On remand the Social Security Administration’s Appeals Council affirmed ALJ Ellis’s
finding that Watts became disabled as of December 21, 2018. In so ruling, the Appeals
Council vacated the portion of ALJ Ellis’s decision addressing any disability

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determination before December 20, 2018. The Appeals Council directed another ALJ to
reevaluate whether Watts was disabled between June 1, 2008 and December 20, 2018.
B
In January 2023, ALJ Deborah Geisen conducted Watts’s fifth hearing on his claims—
limited to the period before December 21, 2018. ALJ Geisen applied the familiar five-step
analysis for determining disability. See 20 C.F.R. § 404.1520(a)(4). Although finding that
Watts had a number of severe impairments during the period at issue, ALJ Geisen
determined that they did not (individually or in combination) meet or medically match
the severity of one of the listed impairments in the relevant regulations’ appendix. See 20
C.F.R. Part 404, Subpart P, Appendix 1. From there ALJ Geisen determined that Watts
had the residual functional capacity to perform light work subject to several additional
limitations. Because Watts could perform his prior job as a cleaner, ALJ Geisen concluded
he was not disabled before December 21, 2018.
The district court upheld the ALJ’s determination.
II
To warrant reversal, Ms. Watts must show that the ALJ committed legal error or that
her decision was not supported by substantial evidence. See Gedatus v. Saul, 994 F.3d 893,
900 (7th Cir. 2021). Substantial evidence is not a demanding standard. It requires only
“such relevant evidence as a reasonable mind might accept as adequate to support a
conclusion.” Biestek v. Berryhill, 587 U.S. 97, 103 (2019) (quoting Consol. Edison Co. v. NLRB,
305 U.S. 197, 229 (1938)). And our review is limited: “[w]e will not reweigh the evidence,
resolve debatable evidentiary conflicts, determine credibility, or substitute our judgment
for the ALJ's determination so long as substantial evidence supports it.” Gedatus, 994 F.3d
at 900.
Ms. Watts challenges ALJ Geisen’s decision to give Dr. Frey’s opinion only “limited
weight” in the RFC analysis. Ms. Watts suggests that the ALJ offered inadequate reasons
to reject the work-related limitations that Dr. Frey identified as necessary for Watts in the
period before December 21, 2018. Not so in our view.
ALJ Geisen’s opinion highlights the cursory nature of Dr. Frey’s references to Watts’s
medical records as well as the inconsistency of the limitations Dr. Frey found with
objective medical evidence. The ALJ’s reasoning reflects an adequate application of the
factors that the regulations list for assessing medical opinions. See 20 C.F.R.
§ 404.1527(c)(1)–(6). In short, substantial evidence supported the ALJ’s decision.
Even more, Dr. Frey’s review led her to the same conclusion as the ALJ: Watts’s
medical evidence supports that he initially became disabled on December 21, 2018. It

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therefore seems odd for Ms. Watts to rely on Dr. Frey’s findings or analysis to prove
disability before that date—when Dr. Frey herself did not arrive at that view. Put most
simply, Dr. Frey’s opinion does not “compel[] the conclusion that the adverse disability
decision lacks substantial support in the record.” Morales v. O’Malley, 103 F.4th 469, 470
(7th Cir. 2024).
Ms. Watts next claims that ALJ Geisen failed to properly address Watts’s vascular
dementia and associated cognitive defects. In cataloging Watts’s mental impairments,
ALJ Geisen acknowledged that Watts “alleged a stroke and vascular dementia.” But the
ALJ concluded neither was a “medically determinable impairment[]” for the period at
issue because “neither of these alleged impairments [was] established by the evidence
prior to December 20, 2018.” Instead, based on the medical record and Watts’s activities,
the ALJ concluded that Watts had only mild or moderate mental impairments during the
period at issue.
Ms. Watts counters with evidence she suggests not only reveals greater cognitive
impairment than ALJ Geisen found, but also shows that her late husband suffered from
vascular dementia before December 2018. Here, too, we cannot agree.
ALJ Geisen in no way ignored the evidence that Ms. Watts emphasizes on appeal.
Instead, the ALJ concluded that the record supports less severe cognitive impairment.
And Ms. Watts “did not provide any opinion from a doctor who would have imposed
greater restrictions than those the ALJ found in [her] decision.” Tutwiler v. Kijakazi, 87
F.4th 853, 860 (7th Cir. 2023). More specifically, she offers no diagnosis of vascular
dementia prior to Dr. York’s examination in 2018. Absent an opposing medical opinion,
Ms. Watts’s argument only invites us to reweigh the evidence of Watts’s cognitive
abilities—an invitation we must decline. See id.
For these reasons, we AFFIRM.

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