Hatmaker v. Commissioner of Social Security, 965 F. Supp. 2d 917

Plaintiff Hatmaker timely challenged the SSA Commissioner’s denial of DIB/SSI after a 2010 ALJ decision that found him not disabled.
Plaintiff filed applications for DIB/SSI in Feb 2009 based on lumbar spine degeneration, hypertension, left upper extremity tremor, depression, and anxiety.
ALJ found severe impairments and that Plaintiff could perform light unskilled work with limited left-hand grasping.
Treating physician Dr. Wood provided conflicting mental and physical assessments that the ALJ discounted.
The Magistrate Judge recommended affirming the ALJ’s decision; Plaintiff objected, and the district court adopted the R&R denying relief.
The court’s discussion focused on the treating-source rule, credibility, and the weight given to medical opinions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ properly weighed Dr. Wood’s physical opinion	Hatmaker argues Dr. Wood’s physical restrictions were inadequately weighed	Hatmaker’s physical limitations were not controlling weight and were properly weighed against other evidence	No reversible error; ALJ provided substantial reasons for discounting Wood’s physical opinion
Whether ALJ properly addressed Dr. Wood’s mental limitations	Hatmaker argues ALJ failed to discuss mental limitations from Wood’s opinion	ALJ indirectly addressed mental impairments via other medical evidence and there was harmless error	Harmless error; ALJ’s discussion sufficed to meet the regulatory goal and avoid remand

Allen v. Comm’r of Soc. Sec., 561 F.3d 646 (6th Cir.2009) (adequate explanation suffices when it reaches several regulatory factors)
Buxton v. Halter, 246 F.3d 762 (6th Cir.2001) (treating-source opinion must be well-supported and consistent with record)
Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir.2004) (good reasons required for weight given to treating-source opinions; harmless error possible)