Jeffers v. Commissioner of Social Security, 2:21-cv-04861-ALM-EPD

Plaintiff filed for SSI on June 3, 2019 (DIB claim withdrawn), alleging disabling physical and mental impairments; amended alleged onset date is June 3, 2019.
ALJ found severe impairments: degenerative disc disease (cervical), degenerative joint disease of the left shoulder, depression, anxiety, and borderline personality disorder.
ALJ’s RFC: light work with limits (frequent ramps/stairs, frequent reaching in all directions, occasional stooping, no ladders/scaffolds, avoid hazards, simple routine tasks, no fast-pace/strict quota, no direct public interaction, only occasional coworker/supervisor contact).
Treating APRN Heather Gillespie submitted two Medical Source Statements: a mental statement (moderate and several marked limitations; predicted >2 absences/month; full-time work would likely cause deterioration) and a physical statement (limited to less-than-full-range sedentary work with reaching/handling/fingering and postural restrictions).
ALJ gave Gillespie’s mental opinion "somewhat persuasive" and physical opinion "little persuasive" but did not analyze the supportability of those opinions (i.e., the objective findings and basis Gillespie referenced).
Magistrate Judge Deavers recommends reversal and remand under sentence four of 42 U.S.C. § 405(g) because the ALJ failed to explain how she considered the supportability factor required by 20 C.F.R. § 404.1520c(b)(2), preventing meaningful review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the ALJ properly evaluated and articulated the persuasiveness of treating APRN Gillespie’s medical opinions under the post‑2017 medical‑opinion rule (supportability and consistency).	ALJ failed to discuss supportability; Gillespie expressly documented objective findings supporting her opinions (e.g., chronic neck/shoulder pain, limited ROM); ALJ only compared opinions to the record (consistency), so decision lacks traceable reasoning.	Commissioner contends the decision, read as a whole, shows consideration of supportability and consistency and that record evidence was inconsistent with Gillespie’s disabling limitations.	Magistrate: remand required. ALJ did not explain supportability as required by 20 C.F.R. § 404.1520c(b)(2), so the court cannot meaningfully review the persuasiveness determination.

Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647 (6th Cir.) (substantial‑evidence standard and review of Commissioner’s findings)
Rogers v. Comm’r of Soc. Sec., 486 F.3d 234 (6th Cir.) (definition of substantial evidence and review principles)
Cutlip v. Sec’y of Health & Hum. Servs., 25 F.3d 284 (6th Cir.) (definition of substantial evidence)
Blakley v. Comm’r of Soc. Sec., 581 F.3d 399 (6th Cir.) (deference to ALJ where supported by substantial evidence)
Universal Camera Corp. v. NLRB, 340 U.S. 474 (U.S.) (consideration of evidence that detracts from agency finding)
Henley v. Astrue, 573 F.3d 263 (6th Cir.) (citation describing the sequential evaluation)
Foster v. Halter, 279 F.3d 348 (6th Cir.) (sequential evaluation framework)
Key v. Callahan, 109 F.3d 270 (6th Cir.) (standard on appellate review when evidence could support opposite conclusion)