Jacobs v. Commissioner of Social Security Administration, 1:18-cv-02485

Plaintiff Tushana R. Jacobs filed for DIB and SSI alleging disability from January 16, 2014, based on systemic lupus erythematosus (SLE) and inflammatory/rheumatoid arthritis; administrative denials followed and an ALJ hearing occurred January 11, 2017.
Treating rheumatology records (2014–2016) show multi-joint pain, intermittent synovitis, treatment with hydroxychloroquine, methotrexate, prednisone, and, beginning June 2016, Xeljanz; providers documented periods of active disease but overall improvement on therapy after June 2016.
Treating rheumatologist Dr. Maya Mattar completed a June 19, 2016 Lupus (SLE) RFC Questionnaire: <2 hours total sitting/standing/walking in an 8-hour day; need for unscheduled breaks and lying down; frequent flare-ups and about three absences per month.
State agency reviewers (2014, 2015) assessed a light RFC with up to 4 hours standing/walking and frequent handling/fingering; the ALJ adopted a light RFC with limits (standing/walking 4 hours total; sit 6 hours; frequent handling/fingering; postural limits; avoid concentrated cold).
ALJ found plaintiff not disabled (Feb. 23, 2017); Appeals Council denied review; Magistrate Judge Kathleen B. Burke recommended affirmance, rejecting plaintiff’s treating-physician and closed-period arguments as unsupported by substantial evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ properly applied the treating-physician rule to Dr. Mattar’s June 2016 opinion	Jacobs: ALJ erred by not giving controlling weight to Dr. Mattar, failing to apply/regard the §404.1527(c) factors, and not explaining the weight assigned	Commissioner: ALJ permissibly discounted the opinion because it did not account for post‑treatment improvement on Xeljanz and expressly afforded it "somewhat diminished" persuasiveness; ALJ considered record and other opinions	Magistrate: ALJ gave adequate reasons—opinion inconsistent with later medical improvement—was sufficiently explained for review; no remand warranted
Whether ALJ should have found a closed period of disability (pre‑June 2016)	Jacobs: Even if improved on Xeljanz, the record supports a closed period before improvement consistent with Dr. Mattar’s limitations and unpredictable flare‑ups	Commissioner: ALJ reviewed pre‑ and post‑June 2016 records, relied on objective findings and state‑reviewer RFC, and reasonably concluded the record did not support disability for any continuous period	Magistrate: No reversible error; ALJ’s overall analysis shows substantial evidence against awarding even a closed period, so remand not required

Gayheart v. Comm’r of Soc. Sec., 710 F.3d 365 (6th Cir. 2013) (treating-source controlling-weight standard and consistency/supportability inquiry)
Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (requirement to give "good reasons" when not affording controlling weight to treating opinion)
Cole v. Comm’r of Soc. Sec., 661 F.3d 931 (6th Cir. 2011) (procedural "good reasons" rule; meaningful review requirement)
Bowen v. Yuckert, 482 U.S. 137 (1987) (summary of five-step sequential evaluation framework)
McClanahan v. Comm’r of Soc. Sec., 474 F.3d 830 (6th Cir. 2006) (substantial-evidence standard is conclusive for Commissioner findings)
Jones v. Comm’r of Soc. Sec., 336 F.3d 469 (6th Cir. 2003) (courts must affirm when substantial evidence supports ALJ’s conclusion)