Cheryl Minor v. Commissioner of Social Security, 513 F. App'x 417

Minor filed for disability in April 2007, alleging disability from May 4, 2005 after a motor vehicle accident.
She suffers migraines, post‑traumatic brain injury, fibromyalgia, chronic pain, anemia, and depression with cognitive impairment.
Her treating physicians diagnosed fibromyalgia, cognitive disorder, pain disorder, major depression with panic, and other impairments.
The record shows extensive narcotic injections and long‑term treatment from multiple providers, including pain, neurology, and psychiatry specialists.
The ALJ denied benefits at step five, relying on non‑treating sources and discounting treating opinions; the Sixth Circuit reversed and remanded for a benefits award based on treating‑physician rule and fibromyalgia evidence.
The court ultimately held that substantial evidence supported total disability as of May 4, 2005 and remanded with instructions to award benefits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the ALJ properly weigh treating-source opinions?	Minor’s treating physicians provided controlling input.	Non‑treating sources and objective evidence support the ALJ’s weighing.	No; reversible error; remand for benefits.
Did the ALJ apply the treating-physician rule and its requirements correctly?	The ALJ failed to give controlling weight or proper reasons for the weight of treating opinions.	Regulatory framework allows alternative weighting with explanations.	No; violation requiring remand.
Were the hypothetical questions to the VE sufficiently comprehensive?	Hypotheticals failed to include all limiting impairments (e.g., pain disorder, cognitive deficits).	Hypotheticals captured core RFC; VE testimony supported non‑disabled finding.	No; flawed hypotheticals warrant remand.
Did the ALJ adequately analyze fibromyalgia and related subjective pain with objective evidence?	Fibromyalgia diagnosis and related pain were inadequately considered; reliance on partial records improper.	Objective signs limited and consistent with light work.	No; substantial evidence insufficient; remand for disability finding.

Rogers v. Comm’r of Soc. Sec., 486 F.3d 234 (6th Cir. 2007) (reversing when ALJ ignored fibromyalgia framework and relied on insufficient objective data)
Kalmbach v. Comm’r of Soc. Sec., 409 F. App’x 852 (6th Cir. 2011) (affirming remand for failure to adequately weigh treating sources)
Germany-Johnson v. Comm’r of Soc. Sec., 313 F. App’x 771 (6th Cir. 2008) (per curiam; ALJ selectively parsed medical records in fibromyalgia case)
Preston v. Sec’y of Health & Human Servs., 854 F.2d 815 (6th Cir. 1988) (recognizes fibromyalgia as potential disabling impairment under disability framework)
Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (establishes treating-source rule and weight considerations for medical opinions)