Belnap v. Commissioner of Social Security, 1:22-cv-00202-CEH

Background

Claimant Kelly Ann Belnap applied for Period of Disability and Disability Insurance Benefits on September 13, 2019, alleging onset of November 1, 2017; ALJ hearing held December 10, 2020; ALJ denied benefits January 8, 2021; Appeals Council declined review December 7, 2021.
ALJ found severe impairments including cervical degenerative disc disease with myelopathy/radiculopathy, thoracic stenosis, right rotator cuff tear (post‑repair), major depressive disorder, bipolar disorder, and borderline personality features.
ALJ assessed an RFC for a limited range of light work with multiple physical restrictions and mental limits: simple, routine, repetitive tasks (no production pace), occasional changes, and only superficial interaction with others.
Two medical source opinions at issue: an unsigned/partly unreadable Lake Health Internal Medicine questionnaire noting poor concentration, and a one‑time consultative psychologist (Dr. Paul Josell, Psy.D.) who opined impairments in interpersonal relations, attention/concentration/persistence/pace, and stress tolerance (but not understanding/following directions).
ALJ found Dr. Josell’s opinions only partially persuasive—adopting limitations for superficial interactions, simple tasks, and no fast‑paced/production‑quota work but rejecting broader attention and global stress‑intolerance conclusions as inconsistent with record and partly outside Dr. Josell’s scope.
ALJ found the Lake Health form unpersuasive because it was illegible/unsigned, lacked specific functional limitations, and arose soon after psychotropic medication initiation; ALJ nonetheless addressed concentration by including appropriate RFC limits. The district court affirmed, holding substantial evidence supported the ALJ’s reasoning and RFC.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ’s RFC is unsupported because she failed to properly consider and explain rejection/discounting of two medical opinions (Dr. Josell and Lake Health).	Belnap: ALJ gave no meaningful explanation which evidence contradicted Dr. Josell, failed to address supportability/consistency required by 20 C.F.R. § 404.1520c, mischaracterized the record; Lake Health opinion was dismissed without adequate reasoning and its concentration findings were important.	Commissioner: ALJ adequately explained why each opinion was partly or wholly unpersuasive; even if some phrasing differed, ALJ’s decision reflects consideration of supportability and consistency and incorporated Dr. Josell’s functional limitations into the RFC; Lake Health form was illegible/unsigned and contained no specific functional findings.	Court: Affirmed. Substantial evidence supports the ALJ’s assessment and the ALJ created a logical bridge explaining which parts of Dr. Josell’s opinion were adopted and which rejected; Lake Health form permissibly discounted for illegibility/lack of specificity and RFC addressed concentration concerns.

Key Cases Cited

Rogers v. Comm’r of Soc. Sec., 486 F.3d 234 (6th Cir. 2007) (defines substantial‑evidence standard for administrative findings)
Cutlip v. Sec’y of HHS, 25 F.3d 284 (6th Cir. 1994) (explains substantial evidence as more than a scintilla)
Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647 (6th Cir. 2009) (procedural errors that prejudice claimant require remand)
Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (treating‑physician/opinion articulation obligations and need for an accurate, logical bridge)
Combs v. Comm’r of Soc. Sec., 459 F.3d 640 (6th Cir. 2006) (sets out the five‑step sequential evaluation process)
Walters v. Comm’r of Soc. Sec., 127 F.3d 525 (6th Cir. 1997) (burden of proof allocation at steps one through four)
Landsaw v. Sec’y of HHS, 803 F.2d 211 (6th Cir. 1986) (ALJ may discount unsigned/uncertain medical statements)
Quisenberry v. Comm’r of Soc. Sec., 757 F. App’x 422 (6th Cir.) (opinion lacking specific functional limitations may be found unpersuasive)