Iseman v. Commissioner of Social Security Administration, 1:15-cv-01571

Background

Plaintiff Kelly Ann Iseman applied for DIB and SSI based on cervical and lumbar degenerative disc disease with radiculopathy and bipolar disorder; administrative denials led to an ALJ hearing and unfavorable decision, affirmed by Appeals Council, and then review in district court.
Medical record shows cervical MRI (left lateral disc herniation at C3–4), lumbar degenerative changes at L5–S1, EMG suggesting possible C4–5 radiculitis, ongoing pain management/physical therapy, and treatment notes from neurologists and orthopedics.
Treating physician Dr. Paul Hanahan completed a functional assessment limiting lifting, standing/walking, sitting, and all postural activities and opined significant off-task time and absenteeism; treating psychiatric nurse practitioner Robin (Robin) Krause provided mental health assessments describing marked limitations and estimated missed days.
State agency reviewers (nonexamining physicians/psychologists) concluded milder limitations: light exertional capacity with some left-upper-extremity reaching limits and moderate mental limitations (able to do simple/static tasks, moderate limits in social/pace domains).
ALJ adopted an RFC: 20/10 lb lifting, ~6 hours sit/stand, frequent left-hand handling/fingering, occasional overhead reach, simple-to-moderately-complex tasks, no fast-paced/strict quotas, minimal changes; found Plaintiff could work as a maid and therefore not disabled.
District court reversed and remanded, holding the ALJ failed to give adequate, clear reasons under the treating-source framework for discounting Dr. Hanahan’s opinion (and appeared to conflate Hanahan with other providers), while the ALJ’s treatment of Ms. Krause’s opinion was supported by substantial evidence.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ properly weighed treating physician Dr. Hanahan’s opinion	ALJ failed to give controlling weight or adequate "good reasons" for discounting Hanahan’s functional restrictions	ALJ reasonably found Hanahan’s opinion inconsistent with record and other medical evidence	Remand required for ALJ to explicitly explain weight given to Hanahan’s opinion (ALJ conflated providers and did not give proper reasons)
Whether ALJ properly weighed treating psychiatric nurse practitioner Krause’s opinion	Krause’s assessments should have been given greater weight and credited in the RFC	Krause is not an "acceptable medical source"; ALJ reasonably discounted her opinion as inconsistent and internally contradictory	ALJ’s decision to give Krause little weight was supported by substantial evidence; no remand on this issue alone
Whether the RFC reflected all of Plaintiff’s limitations arising from treating-source opinions	RFC fails to capture limitations in Hanahan’s assessment (e.g., sit/stand, postural, off-task/absences)	RFC based on medical record and state reviewers is sufficient; jobs exist per VE testimony	Court remanded because unresolved weight given to Hanahan could change RFC and Step Five analysis
Whether ALJ met burden at Step Five to identify jobs Plaintiff can perform	ALJ’s Step Five findings rely on RFC that may omit treating physician’s restrictions; VE testimony may not support ruling	VE testimony supported jobs given ALJ’s RFC; ALJ relied on persuasive non-treating opinions	Remand ordered to reassess RFC and then re-evaluate Step Five if Hanahan’s opinion is given more weight

Key Cases Cited

Walters v. Comm’r of Soc. Sec., 127 F.3d 525 (6th Cir.) (standard of review: substantial evidence)
Besaw v. Sec’y of Health & Human Servs., 966 F.2d 1028 (6th Cir.) (definition of substantial evidence)
McClanahan v. Comm’r of Soc. Sec., 474 F.3d 830 (6th Cir.) (finality of Commissioner’s findings if supported by substantial evidence)
Jones v. Comm’r of Soc. Sec., 336 F.3d 469 (6th Cir.) (ALJ decision must be supported by substantial evidence even where record favors claimant)
Rogers v. Comm’r of Soc. Sec., 486 F.3d 234 (6th Cir.) (treating-source rule and need to give reasons)
Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir.) (‘‘good reasons’’ requirement for discounting treating-source opinions)
Rabbers v. Comm’r Soc. Sec. Admin., 582 F.3d 647 (6th Cir.) (factors for weighing medical opinions)
Cruse v. Comm’r of Soc. Sec., 502 F.3d 532 (6th Cir.) (evaluation of opinions from non-acceptable medical sources)
Stanley v. Sec’y of Health & Human Servs., 39 F.3d 115 (6th Cir.) (ALJ may reject opinion that contradicts earlier unexplained opinion)