Downey, Jr. v. Social Security, Commissioner of
2:24-cv-10744
E.D. Mich.Mar 28, 2025Background
- Ronald D. applied for Disability Insurance Benefits (DIB) in September 2021, alleging disability due to physical and mental impairments, including schizophrenia, bipolar disorder, PTSD, and back problems.
- Ronald previously worked as a welder and cited an onset date of disability as September 2, 2021.
- After reviewing medical evidence and vocational expert testimony, the ALJ found Ronald had severe impairments but did not meet or equal the seriousness of listed impairments.
- The ALJ determined that Ronald could not do past relevant work but retained residual functional capacity (RFC) for a reduced range of light work with significant mental and social interaction limitations.
- The ALJ found that jobs existed in significant numbers in the national economy that Ronald could perform and determined he was not disabled.
- Ronald appealed the denial, challenging the ALJ’s assessment of certain medical opinions regarding his mental limitations.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| ALJ's evaluation of state agency opinions | ALJ improperly rejected or speculated about social limits, substituting his judgment | ALJ reasonably found state agency opinions vague and gave more specific RFC | ALJ did not err; more specific, supported social limitations |
| Treatment of Dr. Fachting’s opinion | ALJ "cherry-picked" evidence and didn't properly explain discounting | ALJ cited lack of supporting clinical findings and conflict with controlled symptoms | Sufficient explanation; decision supported by substantial evidence |
| Treatment of Dr. Bogdayvone’s opinion | ALJ failed to explain rationale and relied on too few mental status exams | ALJ cited inconsistency with her notes and conservative treatment | Not error; ALJ validly discounted based on supportive evidence |
| Requirement to discuss record evidence | ALJ ignored relevant, contrary records | ALJ is not required to discuss every record if reasoning is traceable | No reversible error; substantial evidence standard met |
Key Cases Cited
- Preslar v. Sec’y of Health & Human Servs., 14 F.3d 1107 (6th Cir. 1994) (establishes burden-shifting at step five of disability analysis)
- Gentry v. Comm’r of Soc. Sec., 741 F.3d 708 (6th Cir. 2014) (defines scope of court’s review as limited to substantial evidence and legal conformity)
- Biestek v. Berryhill, 139 S. Ct. 1148 (2019) (describes substantial evidence standard for administrative decisions)
- Coldiron v. Comm’r of Soc. Sec., 391 F. App’x 435 (6th Cir. 2010) (RFC is an ALJ determination, not a medical one)
- Cutlip v. Sec’y of Health & Hum. Servs., 25 F.3d 284 (6th Cir. 1994) (reviewing court must affirm if substantial evidence supports the decision)
- Gant v. Comm'r of Soc. Sec., 372 F. App’x 582 (6th Cir. 2010) (ALJ may discount unsupported medical opinions)