May v. Commissioner of Social Security
1:24-cv-00499
S.D. OhioMar 11, 2025Background
- Plaintiff Chelsea R. M. applied for Disability Insurance Benefits (DIB), alleging disability since January 1, 2018, based on psychological conditions.
- Her claim was denied at both the initial and reconsideration stages by the Social Security Administration (SSA).
- An administrative law judge (ALJ) conducted a hearing in January 2024; the unfavorable decision was issued in April 2024 and became final in June 2024.
- The ALJ found severe impairments (including mood disorder, PTSD, ADHD, and alcohol disorder) but concluded that Plaintiff was not disabled, as jobs existed in significant numbers she could perform.
- Plaintiff argued on judicial review that the ALJ had failed to adequately develop the record by not obtaining a consultative medical examination.
- The district court reviewed the record and the parties’ briefing and affirmed the Commissioner’s denial of benefits.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Duty to develop the record / consultative exam | ALJ should have ordered a consultative exam since prior opinions were discounted and record incomplete | ALJ is not required to base RFC on a medical opinion and record was sufficient | Court agreed with Defendant; consultative exam not required here |
| Reliance on state agency reviewer opinions | ALJ erred by partially discounting state agency opinions and relying on his own medical judgment | ALJ can use state agency findings even if not fully persuasive | Use of partially persuasive prior findings was proper |
| Consideration of post-review medical evidence | New records post-dating state agency review should have required a new opinion | Additional evidence did not introduce significant new facts | ALJ's consideration and discussion of later records was adequate |
| Necessity of medical opinion for RFC | ALJ must obtain medical opinion for RFC where medical judgment required | No rule requiring RFC to be based solely on a medical opinion | No per se requirement for medical opinion if record is adequate |
Key Cases Cited
- DeLong v. Comm’r of Soc. Sec., 748 F.3d 723 (6th Cir. 2014) (standard for substantial evidence supporting SSA decisions)
- Moats v. Comm’r of Soc. Sec., 42 F.4th 558 (6th Cir. 2022) (definition and standard of substantial evidence)
- Emard v. Comm’r of Soc. Sec., 953 F.3d 844 (6th Cir. 2020) (substantial evidence can support conflicting conclusions)