Seventh Circuit Clarifies Martin: No Independent Duty for a Second ALJ to Address a Prior ALJ’s Findings on Remand; Substantial Evidence Controls

Introduction

This commentary analyzes the Seventh Circuit’s opinion in Claudette Ann Rabdeau v. Frank Bisignano, No. 24-1691 (7th Cir. Oct. 6, 2025). The case addresses a recurrent problem in Social Security disability adjudication: what obligations does a second Administrative Law Judge (ALJ) have on remand with respect to a prior ALJ’s findings in the same claim? Specifically, the claimant argued that the second ALJ was required to confront and incorporate the first ALJ’s earlier finding that she would miss one workday per month, which—when paired with a new vocational expert’s testimony—would be work-preclusive.

The Seventh Circuit rejects that view and clarifies its 2020 decision in Martin v. Saul. The court holds that a second ALJ on remand is not independently obliged to address a prior ALJ’s findings in the same case so long as the second ALJ’s decision is supported by substantial evidence and the ALJ builds the required logical bridge from the record to the conclusion. Applying that standard, the court affirms the denial of benefits for the period before May 9, 2018, where the medical record reflected generally well-controlled headaches and normal neurological findings, while leaving undisturbed the award of benefits from May 2018 onward.

Summary of the Opinion

Judge Jackson-Akiwumi, writing for a unanimous panel, affirms the district court and upholds the second ALJ’s determination that the claimant, Claudette Rabdeau, was not disabled prior to May 9, 2018. The court emphasizes:

A second ALJ need not discuss a prior ALJ’s findings from earlier proceedings on the same claim if the decision on remand is supported by substantial evidence.
Martin v. Saul does not impose an independent obligation to “grapple with” or reconcile prior ALJ findings; Martin turned on the absence of substantial evidence and improper cherry-picking of the record.
Here, the second ALJ’s analysis adequately weighed the medical record—particularly the treating neurologist’s notes—showing headaches that were generally well controlled prior to a marked deterioration on May 9, 2018. That suffices under the “not high” substantial-evidence threshold.

Because the ALJ’s narrative built a logical bridge and grappled with conflicting evidence, and because the decision was grounded in specific examination findings, the Seventh Circuit affirms.

Case Background

Rabdeau sought disability benefits based on cervical spine degeneration, severe headaches/migraines, and mental impairments, alleging disability since June 13, 2014. Her treating neurologist, Dr. Fallon Schloemer, documented intensive management beginning in 2014, including medication adjustments and Botox injections. From mid-2015 through early 2018, the record repeatedly characterized her headaches as improved or well controlled, notwithstanding intermittent exacerbations. On May 9, 2018, however, she presented with severe head and neck pain that did not respond to escalated interventions, marking the onset of disabling impairment.

Procedurally, a first ALJ (Gendreau) on remand issued a partially favorable decision: disabled from May 9, 2018 forward; not disabled beforehand, though he found pre-2018 absenteeism of one day per month (which did not exceed the first vocational expert’s threshold of more than one day per month). After a second Appeals Council remand, a second ALJ (Freyberg) again denied pre-May 2018 benefits, this time with testimony from a different vocational expert who opined that more than eight annual absences (≈0.67 days per month) would be work-preclusive. The second ALJ did not adopt or discuss the first ALJ’s “one day per month” finding and did not make a specific absenteeism finding; instead, he concluded that the pre-2018 record did not reflect disabling headache severity.

Analysis

Precedents Cited and Their Role

Biestek v. Berryhill, 587 U.S. 97 (2019): Reaffirms that “substantial evidence” is “not high,” requiring only such relevant evidence as a reasonable mind might accept. The Seventh Circuit foregrounds Biestek to frame a deferential standard of review.
Consolidated Edison Co. v. NLRB, 305 U.S. 197 (1938): Source of the canonical definition of substantial evidence, quoted in Biestek and again here.
Jarnutowski v. Kijakazi, 48 F.4th 769 (7th Cir. 2022): Restates the limited scope of appellate review; reversal is warranted only for legal error or lack of substantial evidence.
Gedatus v. Saul, 994 F.3d 893 (7th Cir. 2021): Emphasizes that the court does not reweigh evidence or substitute its judgment if substantial evidence supports the ALJ’s decision.
Denton v. Astrue, 596 F.3d 419 (7th Cir. 2010): Articulates the “logical bridge” requirement—an ALJ need not mention every piece of evidence so long as the ALJ builds a logical bridge from evidence to conclusions.
Martin v. Saul, 950 F.3d 369 (7th Cir. 2020): The claimant’s main precedent. The Seventh Circuit distinguishes Martin, explaining that its concern was not a categorical duty to address prior ALJ findings; rather, it reversed because the second ALJ lacked substantial evidence, ignored significant contrary evidence, and cherry-picked an agency physician’s opinion.
Warnell v. O’Malley, 97 F.4th 1050 (7th Cir. 2024): Illustrates affirmance where the ALJ cited discrete findings, contended with conflicting evidence, and adequately explained why the record led to denial of benefits.
Winsted v. Berryhill, 923 F.3d 472 (7th Cir. 2019): Shows the boundary: reversal is appropriate when an ALJ ignores the vocational implications of a claimant’s most significant limitations. The panel contrasts Winsted to underscore that, here, the second ALJ’s holistic record analysis sufficed.

Legal Reasoning

1) The main legal question and the Martin clarification. The claimant contended that ALJ Freyberg was obligated to address or adopt ALJ Gendreau’s prior finding of “one absence per month.” If carried forward and combined with the second vocational expert’s threshold (>8 absences per year), that would preclude work for the period before May 9, 2018. The Seventh Circuit disagrees that Martin imposes such a duty. Martin does not create an independent, across-the-board requirement for a second ALJ to reconcile or explicitly discuss a predecessor’s findings. Rather, Martin’s reversal turned on the second ALJ’s lack of substantial evidentiary support—cherry-picking and discounting nearly all relevant medical evidence.

Key rule from this case: A second ALJ on remand is not required to address a prior ALJ’s findings in the same case, provided the second ALJ’s decision is itself supported by substantial evidence and includes a reasoned explanation.

2) Substantial evidence review. Applying Biestek’s “not high” standard and Jarnutowski/Gedatus’s deferential review, the court asks whether the second ALJ built a logical bridge from the medical record to the conclusion that pre-2018 headaches were not disabling. The answer is yes. The ALJ:

Synthesized extensive longitudinal treatment notes from Dr. Schloemer (the treating neurologist).
Highlighted consistent normal findings on neurological and motor examinations.
Tracked a multi-year arc of improvement and “well-controlled” headaches from mid-2015 through early 2018, with intermittent but short-lived flare-ups.
Noted the lack of consistent, quantified documentation of headache frequency in the notes prior to May 2018—many references described frequency only in general terms.
Identified May 9, 2018 as a clear inflection point where headaches and neck pain became severe, refractory to treatment (even nerve blocks), and disabling.

This is precisely the kind of evidence-based narrative Denton and Warnell endorse. Accordingly, the court declines to reweigh the evidence or resolve debatable conflicts and affirms.

3) Vocational expert (VE) testimony and absenteeism. The claimant’s theory hinged on combining (i) the first ALJ’s pre-2018 absenteeism finding (one day per month) with (ii) the second VE’s more stringent “>8 absences/year” work-preclusive threshold. But the second ALJ neither adopted nor discussed the prior absenteeism finding and did not make a specific absenteeism finding for the pre-2018 period. The court says that is not reversible error in itself. Unlike in Winsted, where the ALJ ignored VE testimony about the claimant’s primary work limitations, here the second ALJ reasonably explained—by reference to the medical record—why pre-2018 headache severity was not disabling, obviating a specific absenteeism quantification.

4) Treating source evidence. Although the opinion does not canvass the treating-physician regulation framework, the second ALJ effectively gave substantial weight to Dr. Schloemer’s longitudinal records, leaning on those notes for both normal neurological findings and functional control of headaches pre-2018. That further supports the substantial evidence finding.

Impact

Clarifying Martin across the Seventh Circuit. This decision will be cited for the proposition that, in the Seventh Circuit, a second ALJ on remand has no freestanding obligation to engage a prior ALJ’s findings from earlier proceedings in the same claim. Martin does not require a comparative discussion or reconciliation; it stands for the familiar proposition that an ALJ must avoid cherry-picking and must ground conclusions in substantial evidence.

Practical consequences in Social Security litigation.

Arguments predicated on prior ALJ findings will carry less force unless tied to current record evidence. Claimants cannot rely on a predecessor ALJ’s findings (e.g., absenteeism estimates) as quasi-binding. Counsel must instead develop the evidentiary record to compel the same functional conclusions under the substantial-evidence standard.
Record specificity matters. The court highlighted that Dr. Schloemer’s notes often did not quantify headache frequency. On remand or further proceedings, quantified metrics (days per month, duration, functional impact) and opinion evidence that operationalizes those metrics into vocational terms will be critical.
Different VEs, different thresholds. This opinion tacitly accepts that vocational evidence can vary across hearings (e.g., one day per month vs. >8 days per year). Such variation, without more, is not error. What matters is whether the ALJ’s ultimate conclusions are supported by the medical and vocational evidence actually credited.
Scope of remand orders remains pivotal. When the Appeals Council remands for specific concerns (as here, to address headache evidence more fully), the second ALJ must comply with those instructions. But absent a directive to adopt prior findings, this decision confirms the ALJ’s latitude to reassess the record.
Standard of review discipline. District courts and the Seventh Circuit will be reluctant to reverse where the ALJ builds a logical bridge and marshals discrete examination findings—even if another adjudicator might have weighed the same record differently.

Relation to doctrines in other contexts. This case concerns successive ALJ decisions on the same claim after remand. Some circuits apply res judicata or “law of the case” concepts to subsequent applications (e.g., Chavez, Drummond/Albright). This opinion does not extend such doctrines to require a second ALJ to adopt prior findings within the same claim; instead, it centers the substantial-evidence inquiry. Practitioners should be careful not to conflate the two contexts.

Complex Concepts Simplified

Substantial evidence: A low, deferential standard. The question is not whether the court would have decided differently, but whether a reasonable person could accept the evidence as adequate to support the ALJ’s conclusion. The bar is “not high.”
Logical bridge: The ALJ must connect the dots—explain how specific pieces of evidence lead to the ultimate findings. The ALJ need not discuss every document but must show a reasoned path.
Residual Functional Capacity (RFC): What a claimant can still do, despite impairments, in a work setting. RFC is assessed with medical and nonmedical evidence and drives the vocational analysis.
Vocational Expert (VE): A specialist who testifies about job availability and how specific limitations (including absenteeism) affect employability.
Work-preclusive absenteeism: VEs often identify thresholds (e.g., exceeding one day per month or eight days per year). Exceeding those levels typically eliminates competitive employment. But an ALJ must first find, based on the record, that such absenteeism would occur.
Cherry-picking: Improperly relying only on evidence that supports non-disability while ignoring significant contrary evidence. Martin condemned cherry-picking; the Seventh Circuit found no such problem here.
Appeals Council remand: The Appeals Council can remand an ALJ decision for further proceedings with instructions. On remand, the ALJ must follow those instructions but is not necessarily bound to adopt prior findings unless directed.

Application to the Facts

The court canvassed a detailed medical record:

2014–early 2015: Imaging showed degenerative changes; headaches were frequent and severe; medications adjusted; Botox initiated.
Mid-2015–2016: Headaches decreased from daily to twice weekly and then to once or twice a month; although intensity sometimes increased, overall control improved; neurological exams remained normal.
2017–early 2018: Generally well controlled with occasional exacerbations addressed by medication adjustments.
May 9, 2018: Marked deterioration with acute head/neck pain unresponsive to aggressive interventions; thereafter, headaches and pain were disabling.

Against this backdrop, the second ALJ concluded that, “whatever the frequency of the migraines may have been, their severity does not appear to have been disabling” prior to May 2018, a conclusion the Seventh Circuit deemed supported by substantial evidence. The absence of a specific pre-2018 absenteeism finding did not undermine the decision where the ALJ adequately explained why the severity and functional impact did not rise to disability during that period.

Practice Pointers

For claimants: Do not assume a prior ALJ’s favorable granular findings (e.g., predicted absences) will carry forward. Build a quantified and contemporaneous record—treatment logs, clinician notes documenting frequency/duration, and medical source statements translating symptoms into vocational terms.
For ALJs: Ensure compliance with Appeals Council remand directives and document a logical bridge using discrete examination findings, especially when record descriptions are qualitative (“somewhat increased” or “short lived”). Address both improvement and flare-ups.
For advocates: When arguing Martin, anchor the critique in evidentiary gaps—cherry-picking or failures to address significant contrary evidence—rather than in a stand-alone duty to reconcile prior ALJ findings.

Conclusion

Rabdeau v. Bisignano refines the Seventh Circuit’s Social Security jurisprudence by clarifying that Martin v. Saul does not impose an independent requirement for a second ALJ on remand to discuss or adopt a prior ALJ’s findings. The controlling question remains whether the ALJ’s decision is supported by substantial evidence and whether the ALJ has built a logical bridge from the record to the conclusion. On the merits, the court finds that the second ALJ reasonably relied on longitudinal treatment notes showing largely well-controlled headaches and normal neurological examinations before a clear deterioration on May 9, 2018. The affirmance underscores a deferential standard of review and signals to practitioners that the path to reversal lies in demonstrating evidentiary deficiencies—such as ignoring material contrary evidence—rather than simply pointing to differences between successive ALJs’ findings.