The 7th Circuit Court of Appeals has affirmed a ruling by an administrative law judge (ALJ) denying disability insurance benefits to a man, Chris Martin, who waited over 18 months to see a doctor after injuring his back at work in June 2016. Martin finally saw a doctor in February 2018 and was diagnosed with a spine disorder in May 2018. He subsequently applied for supplemental security income benefits and disability insurance benefits, asserting that he had been disabled since June 2016.

However, the ALJ did not agree with his claims, due to a lack of medical evidence indicating he was disabled earlier than his initial doctor’s visit in 2018. Despite Martin’s appeal, the Social Security Appeals Council endorsed the ALJ’s decision. Martin took his case to the United States District Court for the Southern District of Indiana arguing that the ALJ was incorrect in not consulting an additional medical expert to assess the medical evidence, and in dismissing his testimony about his symptoms.

Despite his efforts, the district court upheld the partial denial of benefits. The 7th Circuit agreed with the district court, stating that according to Social Security Ruling 18–01p, an ALJ is not mandated to consult a medical expert for such cases, and such a decision is at the discretion of the ALJ. The appellate court found that there was adequate evidence supporting the onset date identified by the ALJ.