Coontz v. SSA, 5:16-cv-00332

Plaintiff Janet Faye Coontz sought judicial review under 42 U.S.C. § 405(g) after the ALJ denied her disability insurance benefits claim (alleged onset August 27, 2013).
The ALJ applied the five-step sequential evaluation and found Coontz has severe impairments of low back pain/lumbago with degenerative lumbar disc and right carpal tunnel syndrome.
The ALJ found Coontz does not meet or equal a Listing and assigned an RFC for a reduced range of medium work with frequent handling/fingering, limited climbing (no ladders), and no unprotected heights/ vibration.
The ALJ gave the treating physician Dr. Craig Enlow’s November 2014 opinion little weight, citing inconsistencies with his own treatment notes (normal gait, normal strength/tone, lack of documentation for alleged deficits, and no prior cane recommendation) and subsequent pain-management notes showing symptom control with medication.
The ALJ considered but declined to find Coontz’s left-thumb endstage osteoarthritis a separate severe impairment, noting treatment with injection and lack of follow-up suggesting a good response and no objective evidence that it prevented lifting 50 pounds.
The ALJ concluded Coontz could perform her past relevant work as a material handler; alternatively, other jobs exist in the national economy, so she is not disabled. The district court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ gave insufficient reasons for discounting treating physician Dr. Enlow's opinion	Enlow's opinion (severe functional limits: sitting/standing/walking 15 min; <2 hours/day; cane; lifting <20 lbs) should receive controlling weight	ALJ argued Enlow's opinion conflicted with his own treatment notes and other medical evidence; ALJ provided good reasons to give it little weight	Held: ALJ provided good reasons; substantial evidence supports giving little weight to Enlow's opinion
Whether ALJ erred by not finding left-thumb endstage osteoarthritis a severe impairment	Coontz argued the thumb arthritis is severe and limits lifting	ALJ acknowledged diagnosis and treatment, found injection response and no objective evidence of functional limitation preventing medium work; non-severe finding does not omit consideration of limitations	Held: No reversible error—ALJ considered the condition in the RFC and substantial evidence supports the result

Rabbers v. Comm'r Soc. Sec., 582 F.3d 647 (6th Cir. 2009) (standard of review: substantial evidence and proper legal standards)
Walters v. Comm'r of Soc. Sec., 127 F.3d 525 (6th Cir. 1997) (description of the five-step sequential evaluation)
Kirkland v. Comm'r of Soc. Sec., [citation="528 F. App'x 425"] (6th Cir. 2013) (ALJ must consider both severe and nonsevere impairments when assessing RFC)
Fisk v. Astrue, [citation="253 F. App'x 580"] (6th Cir. 2007) (failure to find additional severe impairments is not reversible error if ALJ considered all impairments in RFC)