Jandle v. Commissioner of Social Security, 1:17-cv-00078

Melissa Jandle applied for DIB and SSI (April 2014), alleging disability from January 1, 2009; relevant period began July 29, 2011. ALJ Motta denied benefits on Feb. 1, 2016; Appeals Council denied review. Case remanded recommendation filed Jan. 8, 2019.
Primary impairments found severe: depressive disorder and PTSD; RFC limited to less-than-full range of medium work with multiple nonexertional restrictions (simple repetitive tasks, low stress, no public contact, occasional coworker/supervisor contact, no driving).
ALJ found Jandle could perform past relevant work as a cook helper and alternative substantial numbers of light/medium unskilled jobs via VE testimony.
Disputed evidence: treating family physician Dr. Jewel Stevens’s September 2015 medical source statement (moderate limits; ≥5 unscheduled absences/month) and consultative psychologist Dr. Nancy Schmidtgoessling’s June 2014 evaluation (significant interpersonal/stress limitations).
Jandle’s sole assignment of error: ALJ erred in weighing medical opinions (Drs. Stevens and Schmidtgoessling).
Magistrate Judge concluded the ALJ gave legally adequate reasons supported by substantial evidence for discounting parts of both opinions and that RFC nonetheless accommodated many of their assessed limitations; recommended affirming the Commissioner.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ improperly discounted treating physician Dr. Stevens’s opinion	Stevens’s long‑term treatment relationship and clinical findings support her assessed limitations and absences; ALJ misapplied treating‑source rules	ALJ gave "good reasons" (lack of specialty, inconsistency with treatment notes, unsupported checkbox on absences) and incorporated supported limitations into RFC	ALJ’s analysis satisfied regulatory factors; giving little weight to unsupported portions of Stevens’s opinion was supported by substantial evidence
Whether ALJ improperly discounted consultative examiner Dr. Schmidtgoessling’s opinion	Schmidtgoessling’s findings were consistent with record and state reviewers who adopted limitations; ALJ failed to explain internal inconsistencies	ALJ permissibly found the one‑time exam and some observations inconsistent with hearing demeanor and broader record; RFC still adopted many consultative limits	ALJ reasonably discounted parts of the consultative opinion; any error harmless because RFC included many of its limits

Rabbers v. Comm'r of Soc. Sec., 582 F.3d 647 (6th Cir. 2009) (framework on claimant/Commissioner burdens in five‑step process)
Wilson v. Comm'r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (ALJ must give "good reasons" for weight given to treating physician)
Gayheart v. Comm'r of Soc. Sec., 710 F.3d 365 (6th Cir. 2013) (treating‑source controlling‑weight two‑part test and consistency/supportability factors)
Cole v. Astrue, 661 F.3d 931 (6th Cir. 2011) (procedural requirement to explain weight given treating opinion)
Buxton v. Halter, 246 F.3d 762 (6th Cir. 2001) (ALJ not bound by conclusory doctor statements unsupported by objective criteria)
Richardson v. Perales, 402 U.S. 389 (U.S. 1971) (standards for substantial evidence in administrative proceedings)