Minix v. SSA, 7:16-cv-00236

Linda Minix applied for Disability Insurance Benefits alleging onset January 28, 2013; ALJ denied benefits and Appeals Council declined review, making the October 14, 2015 ALJ decision final.
Claimant was in her early 50s with a GED and past relevant work as assistant store manager, store manager, and dental receptionist; primary complaints were lumbar spine pain and bilateral wrist problems.
Treatment records (family physician Dr. Ira Potter) showed largely stable exam findings (normal gait, strength, straight-leg raise, intact motor/sensation), but Potter completed restrictive check-box opinions limiting lifting, standing/walking, sitting, and hand manipulation.
Consultative examiner Dr. Stephen Nutter found normal gait, normal straight-leg raise, 5/5 grip strength, some dorsolumbar ROM loss and left wrist tenderness but did not supply numeric functional limits.
Medical expert Dr. Louis Fuchs and state-agency reviewer Dr. Jack Reed assessed residual functional capacity (RFC) consistent with light work and additional postural/manipulative/environmental limits; the ALJ gave Fuchs great weight and Reed considerable weight but afforded Potter’s opinions little weight.
ALJ concluded claimant retained RFC for light work with specific limits, could perform past relevant work and other jobs, and therefore was not disabled; district court affirmed on substantial-evidence review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALJ properly evaluated treating physician Dr. Potter’s opinions	Potter’s check-box opinions accurately reflect disabling limitations and should be credited	ALJ reasonably discounted Potter’s opinions as inconsistent with his own treatment notes and objective record	ALJ permissibly gave Potter’s opinions little weight; substantial evidence supports that decision
Whether ALJ improperly relied on medical expert Dr. Fuchs without reviewing all records	Dr. Fuchs failed to consider remote 1999 surgery report and 2014 lumbar x-ray, so his RFC is unreliable	Record shows Dr. Fuchs considered the evidence supporting his RFC; no indication he ignored material records	Court rejected plaintiff’s claim; Fuchs’s opinion was properly considered and given great weight
Whether RFC and step‑4 finding lack substantial evidence	ALJ understated claimant’s limitations and misweighed evidence such that RFC is unsupported	ALJ considered treating, examining, consultative, and state-agency opinions and vocational testimony; any contrary weighing is for the factfinder	RFC and step‑4 determination are supported by substantial evidence; ALJ’s credibility and weighing determinations affirmed

Preslar v. Sec’y of Health & Hum. Servs., 14 F.3d 1107 (6th Cir. 1994) (outlining the five‑step disability evaluation)
Ulman v. Comm’r of Soc. Sec., 693 F.3d 709 (6th Cir. 2012) (court will not reweigh evidence or resolve credibility anew)
Foster v. Halter, 279 F.3d 348 (6th Cir. 2001) (defining substantial evidence standard)
Walters v. Comm’r of Soc. Sec., 127 F.3d 525 (6th Cir. 1997) (discussing credibility where objective evidence is sparse)
Kyle v. Comm’r of Soc. Sec., 609 F.3d 847 (6th Cir. 2010) (affirming where ALJ’s decision is supported by substantial evidence)
Barnhart v. Thomas, 540 U.S. 20 (2003) (deference to Commissioner’s regulations)