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Zombie Gwyneth Paltrow: postpartum feeling zombie-like

May 1, 2012

This post is an opportunity to link some current pop culture to Federal Court opinions. Gwyneth Paltrow poured her heart out MSN reports she said after the birth of her son, she experienced a period of postpartum depression where she “felt like a zombie“. This is actually a somewhat common phrase in the Federal Court zombie opinions.

zombie gwyneth paltrow There are 52 federal court opinions that include a similar phrase (feel, felt, feeling, like a zombie or zombie-like). All but two of these opinions also include some reference to the word “medication” (recall about 51% of the total 310 zombie opinions include the word medication, so the proportion of medication-opinions in this set of “feel like” opinions is significantly higher than average). Additionally the vast majority of these 52 feel-like cases are claims against the Commissioner of Social Security as an appeal of denied benefits. Nearly all of the instances are the Court citing a transcript of testimonial claims that some medication (psycho-pharmaceuticals or painkillers) caused a zombie condition (in the medical history of the plaintiff seeking benefits). I have listed a full list of these quotes below.

The first is Powell v. Shalala decided in 1993, remanding the case for further consideration of disability benefits under the Social Security Act. The alleged disability: high blood pressure. The ruling determined this was not a disability under statute, but the Court says that determination was erroneous without at least hearing the medical evidence.

That defendant is Donna Shalala, former Secretary of Health and Human services. Not sure why she is named defendant and not commissioner of social security. A quick scan of the rest and you’ll notice that nearly all of the cases are with defendant Astrue (36 of 62, more than 2/3rds). Michael Astrue is the current Commissioner of Social Security since 2007 and there are also three other cases that name the defendant only as “Commissioner of Social Security” during Astrue’s tenure and also a prior cases naming Astrue’s predecessors: Callahan, Apfel, Barnhart. The emphasis on Astrue shows how new this feels-like-zombie phraseology is and how rapidly it has grown in the past few years. Presumably it is unrelated to Astrue’s interests in classic literature (he is extensively published as a translator and poet, under his pseudonym, AM Juster, see wikipedia: Astrue).

The two non-medication feels-like-zombie cases are Turner v. Wong decided 2009 (zombie from using PCP angel dust) and Vega v. Hill decided 2005 (zombie from bad headaches). And aside from these two cases, there are four more yes-medication but non-Social-Security zombie-cases, Weeden v. Sear Roebuck & Co. decided 1999 (about employee termination under Family Medical Leave Act), Homesley v Freightline Corp. decided 2003 (affirming damages for claim of sexual harassment), Woods v Wills decided 2005 (about Americans with Disabilities Act and Fair Labor Standards Act, and about a boarding school that forced Thorazine on the students), and Dejesse v. First Judicial Dist of Pa. decided 2007 (about employment discrimination regarding disability). The rest are social security related.

Of the social security related cases, 21 of 46 (45.6%) resulted in a remand for further determination by the social security administration (the others affirmed). That actually seems like a rather high percentage of remands. If that many social security administration results are regularly overturned by federal courts that would seem to be a lot(?). But of course not every case gets a written federal court opinion so perhaps this percentage of written opinions resulting in remand is not unusually high. Honestly, I have no idea what percentage of social security cases with written federal court opinions are remanded.

Here are all the feel-like-zombie quotes from the Federal Court opinions:
from search string: opinions(zombi!) and [(feel! or felt) w/3 ((like w/2 zombie) or “zombie-like”))] :

but first, a wordle cloud made from the same quotes:
Wordle: feel like zombie

“sometimes I feel just like a zombie” – Powell v. Shalala (1993)

“feels like a zombie and only wants to sleep” – Orr v. Charter (1997)

“taking even one-half of a pill, made her feel “like a zombie.” ” – Mygrant v. Callahan (1998)

“cannot take her medications every day because they make her feel “like a zombie” and add to her depression.” – Beckley v. Apfel (1998)

“he does not remember much about the weekend because of the effects of his medications and his anxiety. He says he felt “sort of like a zombie.”” – Weeden v. Sears Roebuck & Co. (1999)

“When she was on medical leave, she felt like “a zombie” and spent days in bed crying, avoiding her friends, and rarely leaving her house ” – Homesley v. Freightliner Corp. (2003)

“medication for anxiety makes her “like a zombie … you’re in another world.” … when her medications are increased she feels “like a zombie.” ” – Arruda v. Barnhart (2004)

“Dr. Williams discontinued one anti-psychotic medication when claimant complained it made her feel like a zombie, but noted that claimant agreed to try another anti-psychotic” – Langley v. Barnhart (2004)

“medical care for “bad headaches, sleeplessness, dizziness, etc.” and feels like a “zombie.” ” – Vega v. Hill (2005)

“she suffered from missed periods, felt like a zombie, experienced “increased passivity,” ” – Woods v. Wills (2005)

“the medications make him dizzy and sleepy and that he feels like a zombie. ” – Ramos v. Barnhart (2006)

“not being able to concentrate and physical limitations of feeling “like a zombie” due to medications and tiring after one hour of work ” – McCormick v. Astrue (2007)

“At times I was so tired that I felt like a zombie.” – DeJesse v. First Judicial Dist. of Pa. (2007)

“she stopped taking her anxiety medications because they made her feel like a zombie. ” – Myers v. Astrue (2008)

“Seroquel and Klonopin “messed him up” and made him feel like a “zombie” during the day. ” – Croft v. Astrue (2008)

“she had stopped taking the Darvocet prescribed by Bjarnason because it made her feel like a “zombie.”” – Hemminger v. Astrue (2009)

“She testified that Xanax makes her feel “like a zombie.” – Cole v. Astrue (2009)

“constantly nervous, felt agitated, became angry over minor things and felt like a zombie with his medication.” – Koswenda v. Astrue (2009)

“her Xanax dosage was decreased from four times a day to three times a day because she had been feeling “like a zombie” and that even with the decreased frequency it continues to make her feel sleepy. ” – Manuella v. Astrue (2009)

“plaintiff found taking antidepressants made her feel like a zombie. He renewed her correct methadone prescription.” – Goble v. Astrue (2009)

“Plaintiff said the medication made him feel like a “zombie.” Plaintiff also testified he heard voices ” – Serrano v. Astrue (2009)

“Turner reported PCP had “stimulant-like effects.” He also occasionally felt zombie-like and hallucinated. ” – Turner v. Wong (2009)

“Mr. Bloom was “explosive,” “edgy,” “manic,” and that he felt “like a zombie.”” – Bloom v. Astrue (2009)

” off the Concerta for a while because it made her feel like a zombie. Plaintiff had put her back on Adderall, which helped with school, but it made her very moody and cranky. Her teachers reported continued poor behavior. ” – Bausley v. Astrue (2009)

“stopped taking his medication because he felt like a “zombie.” – Murphy v. Astrue (2009)

“In terms of side effects from the medication, Plaintiff said that she shook, bit her tongue, and felt like a “zombie” and “out of it.” ” – Fuller v. Astrue (2010)

“stopped attending treatments because Seroquel made him feel like a “zombie,”” – Carney v. Astrue (2010)

“Amitriptyline made her tired; Prozac made her feel like a “zombie”; Paxil made her anxious and jittery.” – Davis v. Astrue (2010)

“her medications make her feel like a zombie, but she failed to report side effects of medication ” – Ward v. Astrue (2010)

“She took a number of medications, which made her feel like a zombie.” – Randall v. Astrue (2010)

“reported that all of the medication made him feel like a zombie and knocked him out” – Casey v. Astrue (2010)

“did not want to take medications that made him feel like a zombie. – Berdine v. Astrue (2010)

“discontinued Paxil (which the plaintiff reported made her feel like a zombie), and he updated her medication regime.” – Knight v. Astrue (2010)

“she is currently on medication for her depression, but that she did not take it prior to the hearing because she did not want to ‘feel like a zombie’ and she wanted to remain alert” – Castillo v. Astrue (2010)

“Hollins reported the medications made her feel like a zombie and made it difficult to remember everything she did” – Hollins v. Astrue (2010)

“Plaintiff had discontinued the Zoloft because it made her feel like a zombie. ” – Young v. Astrue (2010)

“reported that certain medications made her feel “spacy” or like a “zombie.” … discontinued Celexa because it made her “feel like a zombie”” – Lundgren v. Astrue (2011)

“said that he “doesn’t feel anything when on medication, feel[s] like a zombie.” ” – Harrison v. Comm’r of Soc. Sec. (2011)

“testified that the medication caused her to experience headaches and feel zombie-like.” – Marmaduke v. Astrue (2011)

“Oxycontin made him feel like a “zombie,”” – Demarco v. Astrue (2011)

“Even though she was compliant with her medication, she did not like the fact that it made her feel like a “zombie.” She stopped going to her psychiatrist eventually because her insurance ran out.” – Carr v. Astrue (2011)

“take her second dose of Adderall. She reported feeling like a zombie in the morning and staying up until 2:00 a.m” – Nance v. Astrue (2011)

“Plaintiff stated that he was not taking medication at the time of the exam because it would make him feel like a “zombie.” Plaintiff reported the “occasional use of cannabis.” Plaintiff indicated that he had “auditory hallucinations” and stated that he would hear “‘people calling [his] name.'” ” – Gallagher v. Astrue (2011)

“Cymbalta increased her flashbacks; Lithium made her feel like a “zombie”; Risperdal and Geodon “were way too sedating ” – Douthit v. Astrue (2011)

“medications as prescribed because they “tend to make her feel like a zombie” and she believed she could not function with that. … claimant complained to her physicians that the medications made her feel “goofy” and like a “zombie.”” – Daigle v. Comm’r of Soc. Sec. (2011)

“get off of them because they make me feel like a zombie or I have no, like my emotions are just there.” – Davis v. Astrue (2011)

“side effects of taking Prozac is that it makes her, “feel like a zombie.” Plaintiff testified that she gets, “very, very nervous” … assertion that she felt “like a zombie” when she took Prozac. … tired. There is no indication that Plaintiff reported feeling like a “zombie” to Dr. Vila. Moreover, her report that she felt “less tired,” seems to contradict her testimony regarding feeling like a “zombie.” – Hernandez v. Comm’r of Soc. Sec. (2011)

“replace morphine with methadone because the morphine made him feel like a zombie.” – Beaulieu v. Astrue (2011)

“He was prescribed Zyprexa but says he felt like a zombie and stopped taking the medication.” – Higginbottom v. Astrue (2011)

“the dosage of Risperdal he was taking made him feel like a zombie, and Dr. Iqbal reduced the dosage” – Macy v. Astrue (2012)

“Sellers described himself as feeling “like a zombie,” “in a trance,” “fatigued” and “dizzy.” ” – Sellers v. Astrue (2012)

“the medication he prescribed her made her feel like a zombie, and that she hadn’t taken medication in years.” – Keck v. Astrue (2012)

And so we see Paltrow’s feeling like a zombie is a condition expressed before in Federal Courts.

Finally, humorously, Gwyneth is in the foreign press too, where ‘zombie’ is still zombie:

“Gwyneth Paltrow avautuu masennuksestaan”:

“Olin kuin zombie, tähti kertoo”

Gwyneth Paltrow e la depressione post-partum:

“Mi sentivo come uno zombie.”

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