Jones v. Commissioner of Social Security, 1:24-cv-00252

Michelle R. Jones applied for Disability Insurance Benefits (DIB) and Supplemental Security Income (SSI) alleging disability beginning August 31, 2019.
Her claims were denied by the Social Security Administration (SSA) and again on reconsideration; an unfavorable ALJ decision followed a hearing.
After an initial remand from the District Court, the case was re-evaluated by a different ALJ, consolidating the original and subsequent applications; the new ALJ issued another unfavorable decision.
Jones then appealed to the District Court, arguing the ALJ failed to properly consider evidence related to her physical impairments and exertional capacity.
The ALJ had found Jones had several severe physical and mental impairments but retained the residual functional capacity (RFC) for light work with specific limitations; Jones could not perform her past work but could perform other light or sedentary jobs in the national economy.

Issue	Plaintiff's Argument	Defendant's Argument	Held
ALJ's logical bridge on physical therapy/cervical findings	ALJ ignored or failed to fully consider PT notes and limitations	ALJ cited and considered PT notes, limitations were self-reported	ALJ provided minimally sufficient articulation; no remand warranted
Whether ALJ “cherry-picked” records	ALJ only referenced evidence supportive of non-disability	ALJ summarized PT/M.D. findings, including contrary evidence	ALJ did not cherry-pick; considered material contrary evidence
Evaluation of exertional impairment (fatigue/sleep, etc.)	ALJ failed to address evidence of fatigue and limitations from Dr. Snyder	Plaintiff had normal stamina/ability per doctor, no disabling fatigue	ALJ gave reasonable explanation; alternative finding on sedentary jobs suffices
Correct legal standard application	ALJ used improper “significant worsening” standard	ALJ properly considered symptom stability, not required worsening	No improper standard applied; plaintiff’s concern merely semantic

Schmidt v. Barnhart, 395 F.3d 737 (standard for substantial evidence review in SSA appeals)
Clifford v. Apfel, 227 F.3d 863 (reversal standard: lack of substantial evidence or application of erroneous legal standard)
Golembiewski v. Barnhart, 322 F.3d 912 (ALJ may not ignore contrary evidence entirely)
Carlson v. Shalala, 999 F.2d 180 (ALJ must minimally articulate reasoning)
Flener ex rel. Flener v. Barnhart, 361 F.3d 442 (appropriate to rely on SSA medical experts)
Rice v. Barnhart, 384 F.3d 363 (disagreements with an ALJ’s phraseology do not constitute legal error)