Tina Kangail v. Jo Anne B. Barnhart, Comm'r of Soc. Sec., 454 F.3d 627 (7th Cir. 2006). · Go Syfert
Tina Kangail v. Jo Anne B. Barnhart, Comm'r of Soc. Sec., 454 F.3d 627 (7th Cir. 2006). Cases Citing This Book View Copy Cite
258 citation events (258 in the last 25 years) across 20 distinct courts.
Strongest positive: (SS) McCormick v. Commissioner of Social Security (caed, 2024-06-27)
Treatment trajectory · 2006 → 2026 · click a year to view as-of
2006 2016 2026
Top citers, strongest first. 50 distinct citers. How cited ↗
discussed Cited as authority (verbatim quote) (SS) McCormick v. Commissioner of Social Security
E.D. Cal. · 2024 · quote attribution · 1 verbatim quote · confidence high
mental illness in general . . . may prevent the sufferer 9 from taking prescribed medications or otherwise submitting to treatment
examined Cited as authority (verbatim quote) Kampert v. O'Malley
N.D. Ill. · 2024 · signal: see, e.g. · quote attribution · 1 verbatim quote · confidence high
when an applicant for disability benefits both has a potentially disabling illness and is a substance abuser, the issue for the administrative law judge is whether, were the applicant not a substance abuser, she would still be disabled.
discussed Cited as authority (verbatim quote) Doremus v. Commissioner of Social Security
N.D. Ind. · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
ental illness in general ... may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment.
discussed Cited as authority (verbatim quote) Cady, Christopher v. Kijakazi, Kilolo
W.D. Wis. · 2023 · quote attribution · 1 verbatim quote · confidence high
ental illness in general and bipolar disorder in particular . . . may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment.
discussed Cited as authority (verbatim quote) Kuemmel, Jr. v. Commissioner of Social Security (2×) also: Cited "see, e.g."
N.D. Ind. · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
ental illness . . . may prevent the sufferer from taking prescribed medicines or otherwise submitting to treatment.
discussed Cited as authority (verbatim quote) Morrison v. Commissioner of Social Security (2×) also: Cited as authority (rule)
N.D. Ind. · 2023 · signal: see · quote attribution · 1 verbatim quote · confidence high
ipolar disorder can precipitate substance abuse, for example as a means by which the sufferer tries to alleviate her symptoms.
examined Cited as authority (verbatim quote) Schuler v. Commissioner of Social Security
N.D. Ind. · 2022 · quote attribution · 1 verbatim quote · confidence high
thought the medical witnesses had contradicted themselves when they said the plaintiff's mental illness was severe yet observed that she was behaving pretty normally during her office visits. there was no contradiction.
discussed Cited as authority (verbatim quote) Combs v. Kijakazi (2×) also: Cited as authority (rule)
N.D. Ill. · 2022 · signal: see · quote attribution · 1 verbatim quote · confidence high
bipolar disorder can precipitate substance abuse, for example as a means by which the sufferer tries to alleviate her symptoms
discussed Cited as authority (verbatim quote) Lapole v. Commissioner of Social Security
N.D. Ind. · 2021 · signal: see also · quote attribution · 1 verbatim quote · confidence high
ental illness in general and bipolar disorder in particular . . . may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment.
discussed Cited as authority (verbatim quote) Walton v. Kijakazi (2×) also: Cited as authority (rule)
E.D. Wis. · 2021 · signal: see · quote attribution · 1 verbatim quote · confidence high
he fact that substance abuse aggravated mental illness does not prove that the mental illness itself is not disabling.
discussed Cited as authority (verbatim quote) Cuchna v. Saul
N.D. Ill. · 2020 · signal: see also · quote attribution · 1 verbatim quote · confidence high
bipolar disorder can precipitate substance abuse, for example as a means by which the sufferer tries to alleviate her symptoms
discussed Cited as authority (verbatim quote) Black, Jr. v. Saul
N.D. Ill. · 2020 · signal: see · quote attribution · 1 verbatim quote · confidence high
ental illness in general ... may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment.
discussed Cited as authority (verbatim quote) Rattler v. Commissioner of Social Security
N.D. Ind. · 2020 · signal: see · quote attribution · 1 verbatim quote · confidence high
mental illness . . . may prevent the sufferer from taking prescribed medicines or otherwise submitting to treatment.
discussed Cited as authority (verbatim quote) Tolve v. Saul
N.D. Ill. · 2020 · signal: see · quote attribution · 1 verbatim quote · confidence high
ental illness in general . . . may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment.
examined Cited as authority (verbatim quote) Rosario v. Saul
E.D. Wis. · 2019 · signal: see · quote attribution · 1 verbatim quote · confidence high
thought the medical witnesses had contradicted themselves when they said the plaintiff's mental illness was severe yet observed that she was behaving pretty normally during her office visits. there was no 9 contradiction; bipolar disorder is episodic.
discussed Cited as authority (verbatim quote) Young v. Berryhill
N.D. Ill. · 2018 · signal: see, e.g. · quote attribution · 1 verbatim quote · confidence high
bipolar disorder can precipitate substance abuse, for example as a means by which the sufferer tries to alleviate her symptoms
examined Cited as authority (verbatim quote) Cuchna v. Berryhill (2×)
N.D. Ill. · 2018 · signal: see also · quote attribution · 2 verbatim quotes · confidence high
when an applicant for disability benefits both has a potentially disabling illness and is a substance abuser, the issue for the administrative law judge is whether, were the applicant not a substance abuser, she would still be disabled
examined Cited as authority (quoted) Barmore v. Saul (2×) also: Cited "see"
N.D. Ill. · 2020 · quote attribution · 1 verbatim quote · confidence low
on january 15, 2018, discussed employers that hired individuals with legal history he was hopeful and interested in seeking employment, and selected seven places on a resource list that he would consider working.
cited Cited as authority (rule) Michael W. v. Commissioner of Social Security
S.D. Ill. · 2026 · confidence medium
Kangail v. Barnhart, 454 F.3d 627, 629 (7th Cir. 2006). 20 C.F.R. §404.1535 (b).
discussed Cited as authority (rule) Sandy S. v. Frank Bisignano, Commissioner of Social Security
N.D. Ill. · 2026 · confidence medium
Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006) (noting that “mental illness in general . . . may prevent the sufferer from . . . submitting to treatment”).
discussed Cited as authority (rule) Megan H. v. Frank Bisignano, Commissioner of Social Security
N.D. Ill. · 2026 · confidence medium
(Id. at 300, 307); see also Jelinek v. Astrue, 662 F.3d 805, 814 (7th Cir. 2011) (remanding where ALJ failed to consider possible explanations for non-compliance other than that claimant did not require treatment); Kangail v. Barnhart, 454 F.3d 627, 629-31 (7th Cir. 2006) (remanding where ALJ did not consider that “mental illness in general . . . may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment”).
discussed Cited as authority (rule) McCullough v. Commissioner of Social Security (2×)
N.D. Ind. · 2025 · confidence medium
Ind. Feb. 14, 2018) (citing Kangail v. Barnhart, 454 F.3d 627, 629 (7th Cir. 2006)).
discussed Cited as authority (rule) Brin v. Bisignano
N.D. Ill. · 2025 · confidence medium
The Court concludes that matter must be remanded so that the ALJ can consider whether or to what extend Plaintiff’s mental health symptoms may have contributed to these behaviors. “[M]ental illness in general and bipolar disorder in particular . . . may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment.” Kangail v. Barnhart, 454 F.3d 627, 629 (7th Cir. 2006) (finding that because the ALJ did not consider this possibility, the decision did not provide a rational basis for the denial of benefits).
cited Cited as authority (rule) James Michael Rancatore Sr. v. Bisignano
N.D. Ill. · 2025 · confidence medium
Ill. 2015) (quoting Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006)).
discussed Cited as authority (rule) Spiller v. Commissioner of Social Security
S.D. Ill. · 2024 · confidence medium
See Larson v. Astrue, 615 F.3d 744, 751 (7th Cir. 2010) (having “symptoms that ‘wax and wane’ [is] not inconsistent with a diagnosis of recurrent, major depression”); Bauer v. Astrue, 532 F.3d 606, 609 (7th Cir. 2008) (a claimant with a chronic disease like bipolar disorder “is likely to have better days and worse days”); Kangail v. Barnhart, 454 F.3d 627, 629 (7th Cir. 2006) (a patient's normal behavior during office visit does not contradict a finding of severe mental illness).
discussed Cited as authority (rule) Khan v. O'Malley
N.D. Ill. · 2024 · confidence medium
“When an applicant for disability benefits both has a potentially disabling illness and is a substance abuser, the issue for the [ALJ] is whether, were the applicant not a substance abuser, [he] would still be disabled.” Kangail v. Barnhart, 454 F.3d 627, 628 (7th Cir. 2006).
discussed Cited as authority (rule) Wilson v. O'Malley
N.D. Ill. · 2024 · confidence medium
The evidence tends to show the plaintiff’s condition caused a lack of insight into her 14 need for treatment, see, e.g.,Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006); Nguyen v. Chater, 100 F.3d 1462, 1465 (9th Cir. 1996), and that her condition caused concerns for at least one employer and plaintiff’s co-workers.
discussed Cited as authority (rule) Zuber, Jay v. Kijakazi, Kilolo
W.D. Wis. · 2024 · confidence medium
But the ALJ must also consider why the claimant may have received only conservative treatment, including whether the claimant’s mental illness “may [have] prevent[ed] the sufferer from taking [his] prescribed medicines or otherwise submitting to treatment.” Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006).
discussed Cited as authority (rule) Bender v. O'Malley
N.D. Ill. · 2024 · confidence medium
Moreover, the Seventh Circuit has emphasized that “mental illness in general . . . may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment.” Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006); see also Blankenship v. Bowen, 874 F.2d 1116, 1124 (6th Cir. 1989) (finding “it is a questionable practice to chastise one with a mental impairment for the exercise of poor judgment in seeking rehabilitation.”).
cited Cited as authority (rule) Huron v. Commissioner of Social Security
N.D. Ind. · 2024 · confidence medium
Huron argues that mental health struggles may be a valid explanation for the absence of mental health treatment, citing to Kangail v. Barnhart, 454 F.3d 627, 629-30 (7th Cir. 2006).
discussed Cited as authority (rule) Holsten, Jamie v. Kijakazi, Kilolo
W.D. Wis. · 2023 · confidence medium
Under 42 U.S.C. § 423 (d)(2)(C), “[a]n individual shall not be considered to be disabled for purposes of this subchapter if alcoholism or drug addiction would (but for this subparagraph) be a contributing factor material to the Commissioner’s determination that the individual is disabled.” The statute is somewhat convoluted, but the court of appeals has given it a straightforward interpretation: “When an applicant for disability benefits both has a potentially disabling illness and is a substance abuser, the issue for the administrative law judge is whether, were the applicant not a s…
discussed Cited as authority (rule) CHARLTON v. KIJAKAZI (2×)
E.D. Pa. · 2023 · confidence medium
See Jelinek v. Astrue, 662 F.3d 805, 814 (7th Cir. 2011); Brace v. Astrue, 578 F.3d 882, 885-86 (8th Cir. 2009); Kangail v. Barnhart, 454 F.3d 627, 630-31 (7th Cir. 2006); Tome v. Schweiker, 724 F.2d 711, 713-14 (8th Cir. 1984); Warne, 2020 WL 6787162 , at *12-13; Tobin v. Commissioner of Soc.
cited Cited as authority (rule) McAchran v. Kijakazi
N.D. Ill. · 2023 · confidence medium
Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006).
discussed Cited as authority (rule) Buczkowski v. Saul (2×) also: Cited "see"
N.D. Ill. · 2023 · confidence medium
(See id. at 646-70 (July 2020 ALJ decision summarizing only June 2020 hearing testimony and repeatedly referencing singular “hearing”), 671-77 (July 2020 exhibit list to ALJ decision with no reference to December 2017 hearing).) Theresa’s December 2017 testimony indicates that she: “couldn’t handle the public anymore” and did not have friends, (id. at 50, 53); sometimes did not leave her home “for months,” (id. at 55); felt “like chopping someone’s head up” or “a cat’s head off,” and is a “danger to society,” (id. at 54-55); hallucinated and believed that “peo…
discussed Cited as authority (rule) KISSEL v. KIJAKAZI
S.D. Ind. · 2023 · confidence medium
We may need to contact the individual regarding the lack of treatment or, at an administrative proceeding, ask why he or she has not complied with or sought treatment in a manner consistent with his or her complaints."); see also Paul v. Berryhill, 760 F. App'x 460 , 465 (7th Cir. 2019) ("ALJs assessing mental illness and bipolar disorder must consider possible alternative explanations before racing to conclusions about noncompliance with medical directives.") (citation omitted); Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006) (recognizing that "mental illness in general and bipolar dis…
discussed Cited as authority (rule) Branch v. Kijakazi
N.D. Ill. · 2023 · confidence medium
The ALJ’s failure to explore these issues and address them in his written decision were critical errors that completely undermine the denial of benefits in this case because “mental illness in general and bipolar disorder in particular . . . may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment.” Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006); see also Melissa A. v. Comm’r of Soc.
discussed Cited as authority (rule) Nimmer v. Kijakazi
N.D. Ill. · 2023 · confidence medium
As such, a case like Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006) – where Judge Posner cited some medical publications for the proposition that bipolar disorder “may prevent the sufferer from taking her prescribed medicines,” 454 F.3d at 630 – is not really applicable.
discussed Cited as authority (rule) Strum v. Commissioner of Social Security
N.D. Ill. · 2023 · confidence medium
Therefore, when a claimant has a potentially disabling illness and is a substance abuser, ALJs must determine whether the claimant would still be disabled “were [he] not a substance abuser.” Id., quoting Kangail v. Barnhart, 454 F.3d 627, 628-29 (7th Cir. 2006) (citing 20 C.F.R. §416.935 ) (emphasis added).
discussed Cited as authority (rule) Franco Sanchez v. Kijakazi
E.D. Wis. · 2023 · confidence medium
In Kangail v. Barnhart, for example, the court found no contradiction when providers observed that the claimant “was behaving pretty normally during her office visits,” and yet concluded that her mental illness was severe. 454 F.3d 627, 629 (7th Cir. 2006).
discussed Cited as authority (rule) MIKNIS v. SAUL
E.D. Pa. · 2022 · confidence medium
Kangail v. Barnhart, 454 F.3d 627, 630-31 (7th Cir. 2006). courts have recognized a mentally ill person’s noncompliance with psychiatric medications can be, and usually is, the result of [the] mental impairment [itself] and, therefore, neither willful nor without a justifiable excuse’” (quoting Pate-Fires, 564 F.3d at 945 )); see also Pounds v. Astrue, 772 F. Supp. 2d 713 , 723 n.21 (W.D.
cited Cited as authority (rule) Blankenship v. Commissioner of Social Security
N.D. Ind. · 2022 · confidence medium
Ill. 2015). “[M]ental illness . . . may prevent the sufferer from . . . submitting to treatment.” Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006) (citations omitted).
discussed Cited as authority (rule) Booher v. Commissioner of Social Security
N.D. Ind. · 2022 · confidence medium
As the Seventh Circuit has emphasized, “mental illness in general and bipolar disorder in particular . . . may prevent the sufferer from . . . submitting to treatment.” Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006); see also Salaam 11 428823, at *8 (collecting cases).
discussed Cited as authority (rule) TARPLEY v. KIJAKAZI
S.D. Ind. · 2022 · confidence medium
In support, he argues that the Seventh Circuit has cautioned ALJs against placing too much weight on the noncompliance of mentally impaired claimants, noting that mental illness "may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment." [Filing No. 18 at 4 (citing Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006)).] Drew T. argues that his erratic medical history and unclear treatment from neurologists is evidence of the impact of his medical conditions.
discussed Cited as authority (rule) Tritch v. Commissioner of Social Security
N.D. Ind. · 2022 · confidence medium
As a result, “[w]hen an applicant for disability benefits both has a potentially disabling illness and is a substance abuser, the issue for the administrative law judge is whether, were the applicant not a substance abuser, she would still be disabled.” Kangail v. Barnhart, 454 F.3d 627, 628 (7th Cir. 2006).
discussed Cited as authority (rule) Kindler v. Commissioner of Social Security
N.D. Ind. · 2022 · confidence medium
However, "Mental illness in general and bipolar disorder in particular ... may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment." Kangail v. Barnhart, 454 F. 3d 627, 630 (7th Cir. 2006).
discussed Cited as authority (rule) Roberts v. Saul
M.D. Penn. · 2022 · confidence medium
But the fact that substance abuse aggravated her mental illness does not prove that the mental illness itself is not disabling.” Kangail v. Barnhart, 454 F.3d 627, 629 (7th Cir. 2006); Voorhees, 215 F. Supp. 3d at 382 n.8 (quoting Kangail); Zuback v. Colvin, No. 4:14-cv-00602-GBC, 2015 WL 5474846 , at *21 (M.D.
discussed Cited as authority (rule) Scott v. Commissioner of Social Security
N.D. Ind. · 2022 · confidence medium
As the Seventh Circuit Court of Appeals has emphasized, “mental illness . . . may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment.” Kangail v. Barnhart, 454 F.3d 627, 630 (7th Cir. 2006); see also Martinez v. Astrue, 630 F.3d 693, 697 (7th Cir. 2011) (“[P]eople with serious psychiatric problems are often incapable of taking their prescribed medications consistently.”); Jelinek v. Astrue, 662 F.3d 805, 814 (7th Cir. 2011) (listing cases).
discussed Cited as authority (rule) Bergland v. Kijakazi
E.D. Wis. · 2022 · confidence medium
In Punzio, the Seventh Circuit said, “As we have explained before, a person who suffers from a mental illness will have better days and worse days, so a snapshot of any single moment says little about her overall condition.” Id. at 710 (citing Larson v. Astrue, 615 F.3d 744, 751 (7th Cir. 2010); Wilson v. Astrue, 493 F.3d 965, 967-68 (8th Cir. 2007); Kangail v. Barnhart, 454 F.3d 627, 629 (7th Cir. 2006)).
discussed Cited as authority (rule) Jerding v. Saul (2×)
N.D. Ill. · 2021 · confidence medium
Plaintiff argues that her work as a home health aid and as a quality controller was an “unsuccessful work attempt” because of the difficulty she had in performing her jobs due to her poor health. “’Gainful employment’ does not include ‘unsuccessful work attempts.’” Kangail v. Barnhart, 454 F.3d 627, 629 (7th Cir. 2006) (quoting 20 C.F.R. § 404.1574 (c)).
cited Cited as authority (rule) PARROTT v. COMMISSIONER OF SOCIAL SECURITY
D.N.J. · 2021 · confidence medium
The ALJ may not ‘play[ ] doctor.’”) (citing Kangail v. Barnhart, 454 F.3d 627, 629 (7th Cir. 2006)).
Retrieving the full opinion text from the archive…
Tina KANGAIL, Plaintiff-Appellant,
v.
Jo Anne B. BARNHART, Commissioner of Social Security, Defendant-Appellee
05-3674.
Court of Appeals for the Seventh Circuit.
Jul 14, 2006.
454 F.3d 627
Frederick J. Daley, Jr., Marcie E. Gold-bloom (argued), Daley, Debofsky & Bryant, Chicago, IL, for Plaintiff-Appellant., Johm Lee (argued), Todd A. Duelos, Social Security Administration Office of the General Counsel, Region V, Chicago, IL, Defendant-Appellee.
Posner, Coffey, Ripple.
Cited by 162 opinions  |  Published
2 passages pin-cited by 2 cases
Pinpoint authority: #45,955 of 633,719
Citer courts: N.D. Illinois (1) · W.D. Washington (1)
POSNER, Circuit Judge.

The plaintiff contests the denial of social security disability benefits that she sought because she is manic depressive (“bipolar,” in the current jargon) and disabled by her mental illness from holding gainful employment. Age 36 at the time of her hearing before the administrative law judge, she had been diagnosed with bipolar disorder more than a decade earlier; a psychiatrist had noted a “severe depressive quality to her life, interrupted by manic episodes of moderate to severe intensity.” She also has a history of alcohol and drug abuse (cocaine), however, and if such abuse is the cause of her disability, she is barred by statute from obtaining benefits. 42 U.S.C. § 423(d)(2)(C); Vester v. Barnhart, 416 F.3d 886, 888 (8th Cir.2005). The administrative law judge thought this was indeed the case, noting that when the plaintiff stopped abusing alcohol and drugs, in March 2000, her condition improved and she was able to work, at least when she took the medication prescribed for her mental illness.

When an applicant for disability benefits both has a potentially disabling illness and is a substance abuser, the issue for the administrative law judge is whether, were the applicant not a substance abuser, she would still be disabled. 20 C.F.R. § 404.1535(b)(1); Brueggemann v. Barnhart, 348 F.3d 689, 694-95 (8th Cir.2003); Bustamante v. Massanari, 262 F.3d 949, 955 (9th Cir.2001); Drapeau v. Massanari, [*629] 255 F.3d 1211, 1214 (10th Cir.2001). If so, she is deemed disabled “independent of your drug addiction or alcoholism” and is therefore entitled to benefits. 20 C.F.R. § 404.1535(b)(2)(h); see Brueggemann v. Barnhart, supra, 348 F.3d at 694-95. The administrative law judge inferred from the improvement in the plaintiffs condition after she got “clean” that her only problem was substance abuse, but in so concluding he rejected abundant medical testimony without giving adequate reasons for doing so; he “played doctor,” as the cases say. Clifford v. Apfel, 227 F.3d 863, 870 (7th Cir.2000); Green v. Apfel, 204 F.3d 780, 781 (7th Cir.2000).

He thought the medical witnesses had contradicted themselves when they said the plaintiffs mental illness was severe yet observed that she was behaving pretty normally during her office visits. There was no contradiction; bipolar disorder is episodic. The judge went so far as to attribute bipolar disorder to substance abuse, although the medical literature, while noting a positive correlation between the two conditions and speculating that alcohol may trigger bipolar symptoms, does not indicate that the disorder itself can be so caused. American Psychiatric Association, Diagnostic and Statistical Manual of Mental Disorders 187, 354 (4th ed.1994); Frederick K. Goodwin & Kay Redfield Jamison, Manic-Depressive Illness 219-25 (1990); Willem A. Nolen et al, “Correlates of 1-Year Prospective Outcome in Bipolar Disorder: Results from the Stanley Foundation Bipolar Network,” 161 Am. J. Psychiatry 1452 (2004); Marcia L. Verduin et al., “Health Service Use Among Persons With Comorbid Bipolar and Substance Use Disorders,” 56 Psychiatric Services 475-76 (2005).

What is clear is the reverse—that bipolar disorder can precipitate substance abuse, for example as a means by which the sufferer tries to alleviate her symptoms. Goodwin & Jamison, supra, at 219-25; Li-Tzy Wu et al., “Influence of Comor-bid Alcohol and Psychiatric Disorders on Utilization of Mental Health Services in the National Comorbidity Survey,” 156 Am. J. Psychiatry 1235 (1999); Edward J. Khantzian, “The Self-Medication Hypothesis of Addictive Disorders: Focus on Heroin and Cocaine Dependence,” 142 Am. J. Psychiatry 1259, 1263 (1985). There was medical testimony that the plaintiff has “a tendency to indiscriminately use drugs and alcohol” during her manic phases, which are frequent—about monthly. But the fact that substance abuse aggravated her mental illness does not prove that the mental illness itself is not disabling. Brown v. Apfel, 192 F.3d 492, 499 (5th Cir.1999); Sousa v. Callahan, 143 F.3d 1240, 1245 (9th Cir.1998).

The administrative law judge attached too much weight to the plaintiffs job experiences after March 2000, when she stopped abusing drugs and alcohol. It is true that if she was gainfully employed between then and the , date of the final hearing on her application for benefits (February 2003), she is not disabled. 20 C.F.R. §§ 404.1520(a)(4)(i), (b); Jones v. Shalala, 21 F.3d 191, 192 (7th Cir.1994); Fischer-Ross v. Barnhart, 431 F.3d 729, 731 (10th Cir.2005). “Gainful employment,” however, does not include “unsuccessful work attempts.” 20 C.F.R. § 404.1574(c); Stevenson v. Chater, 105 F.3d 1151, 1155 (7th Cir.1997); Depover v. Barnhart; 349 F.3d 563, 566 (8th Cir.2003); Morales v. Apfel, 225 F.3d 310, 319 (3d Cir.2000). “Where it is established that the claimant can hold a job for only a short period of time, the claimant is not capable of substantial gainful activity.” Gatliff v. Commissioner of Social Security Administration, 172 F.3d 690, 694 (9th Cir.1999); see also Cole ex rel. Cole v. [*630] Barnhart, 288 F.3d 149, 152-53 (5th Cir.2002) (per curiam); Andler v. Chater, 100 F.3d 1389, 1393 (8th Cir.1996). And though a job that the applicant held for more than six months cannot be deemed an “unsuccessful work attempt,” 20 C.F.R. § 404.1574(c)(5); King v. Chater, 72 F.3d 85, 87 (8th Cir.1995), neither does it count as substantial gainful employment unless the applicant earned a specified minimum amount, which, so far as concerns this case, was $700 a month in 2000 and $740 a month in 2001. 20 C.F.R. § 404.1574(b)(3); Reeder v. Apfel, 214 F.3d 984, 989 (8th Cir.2000); Byington v. Chater, 76 F.3d 246, 249 (9th Cir.1996).

Only one of the plaintiffs jobs after March 2000 — as a deli worker and cashier — lasted more than six months, in fact eight months. Although it started out as a full-time job, it soon became part time because of her mental condition, and as a result over the entire eight-month period she earned only about $9,900. That is very little, but since gainful employment is presumed if the applicant earned more than the specified monthly minimum for more than six consecutive months, 20 C.F.R. § 404.1574(b)(2); see Miles v. Barnhart, 374 F.3d 694, 698 (8th Cir.2004); Lewis v. Apfel, 236 F.3d 503, 515 (9th Cir.2001), the administrative law judge was entitled to count that job as gainful employment, and likewise the plaintiffs job that preceded it (as a telemarketer) because the only reason the plaintiff gave for leaving it was to get a higher-paying job. The consequence, since an applicant cannot obtain benefits for any period during which she was gainfully employed and therefore not disabled, see Fischer-Ross v. Barnhart, supra, 431 F.3d at 731; Frost v. Barnhart, supra, 314 F.3d at 365-66; Jones v. Shalala, supra, 21 F.3d at 192, is that the onset of the plaintiffs claimed disability cannot be dated earlier than when she lost the cashier job, the job she held for eight months after quitting the telemarketing job. SSR 83-20, “Program Policy Statement: Titles II and XVI: Onset of Disability” (PPS-100), 1983 WL 31249, at *2 (S.S.A.1983); Henderson ex rel. Henderson v. Apfel, 179 F.3d 507, 512-13 (7th Cir.1999); Armstrong v. Commissioner of Social Security Administration, 160 F.3d 587, 590 (9th Cir.1998).

But that leaves the remainder of the three-year period during which she was not abusing alcohol or drugs. She held a total of 10 jobs during the three years, and her testimony, backed up by medical evidence, was that she left all but the first (the telemarketing job) either because of “blowing up,” racing thoughts, confrontations with customers and supervisors, or other manic activity; or because of insomnia, inability to concentrate, feeling overwhelmed, or other symptoms of depression; or because of “disappearing,” confusion, or other symptoms of either pole.

The administrative law judge thought the plaintiffs inability to hold a job unimportant because she could work when she took her medicine. And it is true that bipolar disorder is treatable by drugs. But mental illness in general and bipolar disorder in particular (in part because it may require a complex drug regimen to deal with both the manic and the depressive phases of the disease, Donald M. Hilty et al., “A Review of Bipolar Disorder Among Adults,” 50 Psychiatric Services 205-08 (1999); Mark Oflson et ah, “Bipolar Depression in a Low-Income Primary Care Clinic,” 162 Am. J. Psychiatry 2150 (2005)) may prevent the sufferer from taking her prescribed medicines or otherwise submitting to treatment. American Psychiatric Association, Diagnostic and Statistical Manual of Mental Disorders, supra, at 683; Goodwin & Jamison, supra, at 746-62; Annette Zygmunt, “Interventions to[*631] Improve Medication Adherence in Schizophrenia,” 159 Am. J. Psychiatry 1653, 1662 (2002); Stephen Magura et ah, “Adherence to Medication Regimens and Participation in Dual-Focus Self-Help Groups,” 53 Psychiatric Services 310, 313 (2002). The administrative law judge did not consider this possibility.

In sum, the administrative law judge’s opinion does not provide a rational basis for the denial of disability benefits to the plaintiff. The judgment is therefore vacated and the case returned to the Social Security Administration for further proceedings consistent with this opinion.