Jones v. Commissioner of Social Security
3:19-cv-00142
| S.D. Ohio | Mar 5, 2021Background
- Allen Jones III (born 1959) applied for Disability Insurance Benefits and SSI in November 2015, alleging disability beginning September 4, 2015; he was 56 (advanced age) and has at least a high-school education.
- ALJ found severe impairments: substance dependence, lumbar arthropathy, lumbar stenosis, depression, and intellectual disability; no Listing met or equaled.
- ALJ assessed an RFC for medium work with restrictions (no ropes/ladders/scaffolds; occasional ramps/stairs; no crawling; limited stooping/kneeling/crouching/balancing on uneven surfaces; limited pulmonary irritant exposure; simple routine tasks; no production-rate work) and concluded Jones could perform his past work as an automobile detailer.
- Jones challenged the ALJ’s weighing of medical opinions (consultative examiner Dr. Burns and state non‑examining physicians), the ALJ’s reliance on her own reading of MRI/medical data to craft the RFC, and the ALJ’s omission of physical‑therapy records showing functional deficits.
- The district court vacated the ALJ’s decision and remanded under 42 U.S.C. § 405(g) sentence four for further proceedings, directing the ALJ to obtain an acceptable medical source opinion about physical functional limitations and to reevaluate the record under controlling standards.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Weight given to consultative examiner Dr. Burns vs. non‑examining state physicians | ALJ gave Burns too much weight though Burns lacked later evidence (same defect as state doctors) | ALJ permissibly favored an examining physician and accounted for lack of later evidence by giving only "significant, but not great" weight | ALJ's weighting permissible; any error harmless because RFC was more restrictive than Burns' opinion |
| ALJ translating MRI/raw medical data into functional RFC without a medical opinion | ALJ not qualified to convert MRI findings to RFC; no medical source translated MRI into functional limits, so RFC unsupported | Commissioner points to neurologist Dr. Pabaney’s characterization of MRI as "fairly unremarkable" and other treatment notes | Court held Pabaney’s comment did not constitute a functional RFC opinion and the ALJ lacked adequate medical opinion support; RFC unsupported; remand required |
| Failure to consider physical‑therapy records documenting functional deficits | PT notes showed difficulty with steps, sitting, walking, lifting; ALJ failed to consider these functional findings | Commissioner relied on claimant's daily activities and other records to support RFC | Court found ALJ omitted PT functional findings that were material to RFC assessment; omission undermined RFC and supported remand |
| Remedy: remand for benefits vs. further proceedings | Jones sought remand for benefits or, alternatively, further proceedings | Commissioner asked for affirmance | Court found the record did not overwhelmingly show disability; vacated ALJ decision and remanded for further proceedings to develop medical opinion evidence and reassess RFC |
Key Cases Cited
- Blakely v. Comm’r of Soc. Sec., 581 F.3d 399 (6th Cir. 2009) (standards for substantial‑evidence review and weighing opinions)
- Bowen v. City of New York, 476 U.S. 467 (U.S. 1986) (SSA benefits framework and definition of disability)
- Rogers v. Comm’r of Soc. Sec., 486 F.3d 234 (6th Cir. 2007) (credibility and substantial‑evidence principles)
- Warner v. Comm’r of Soc. Sec., 375 F.3d 387 (6th Cir. 2004) (substantial‑evidence standard)
- Gentry v. Comm’r of Soc. Sec., 741 F.3d 708 (6th Cir. 2014) (consideration of combined impairments)
- Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647 (6th Cir. 2009) (legal‑error review even when evidence supports factual findings)
- Wilson v. Comm’r of Soc. Sec., 378 F.3d 541 (6th Cir. 2004) (treating‑source rule and requirement to give "good reasons" for discounting opinions)
- Melkonyan v. Sullivan, 501 U.S. 89 (U.S. 1991) (authority to remand under § 405(g))
- Faucher v. Sec’y of HHS, 17 F.3d 171 (6th Cir. 1994) (standards for awarding benefits vs. remand)
- Felisky v. Bowen, 35 F.3d 1027 (6th Cir. 1994) (RFC and step‑four analysis guidance)
- Deskin v. Comm’r of Soc. Sec., 605 F. Supp. 2d 908 (N.D. Ohio 2008) (limited circumstances where ALJ may rely on common‑sense judgments absent medical opinion)