Monroe v. Commissioner of Social Security, 2:15-cv-03052

John Monroe applied for disability insurance benefits alleging disability from an October 30, 2007 onset due to back injury and depression; insured through December 31, 2009.
Initial ALJ denial (2011) was remanded by this Court; after a supplemental hearing in 2014 the ALJ again denied benefits; Appeals Council denied review, prompting this § 405(g) challenge.
Medical record through the date last insured includes lumbar degenerative findings (MRI/CT), EMG showing sensory neuropathy, conservative treatment, a 2009 physical therapy Functional Capacity Evaluation by Tracy Hiltz limiting claimant to sedentary work, and mixed treating-provider notes about pain severity and stability.
Medical expert (orthopedic surgeon Dr. Kendrick) testified at the hearing and opined an RFC between sedentary and light with restrictions (sit/stand limits, occasional stooping/kneeling, no hazards, no overhead reaching limits supported by record).
ALJ adopted a sedentary RFC (lifting 10–15 lbs, sit 6 hours/day, stand/walk 4 hours/day, occasional postural limits, no hazards, simple routine tasks) and found claimant not disabled through the date last insured.
Monroe appealed, arguing the ALJ: (1) failed to give proper weight to PT Hiltz’s FCE; and (2) inadequately evaluated his subjective pain/credibility. Court affirmed the Commissioner.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Weight given to PT Hiltz (FCE)	ALJ should have given greater weight and fully credited Hiltz’s observations (gait, fatigue, inability to sustain full workday).	Hiltz is an "other source" (not an acceptable medical source); ALJ reasonably gave her limited weight, relied on ME and other record evidence.	ALJ did not err; properly treated Hiltz as an other-source, explained weight, and reasonably relied on Dr. Kendrick’s opinion.
Credibility of pain complaints	ALJ failed to adequately consider and credit Monroe’s pain, its intensity, and effects on work capacity.	ALJ reasonably discounted credibility based on objective findings, conservative treatment, noncompliance, activities, and expert opinions finding allegations disproportionate.	ALJ’s credibility determination is supported by substantial evidence and adequately explained; no reversible error.

Rabbers v. Comm’r of Soc. Sec., 582 F.3d 647 (6th Cir. 2009) (substantial-evidence review standard and deference to Commissioner)
Rogers v. Comm’r of Soc. Sec., 486 F.3d 234 (6th Cir. 2007) (two-step pain/symptom evaluation and requirement to explain credibility findings)
Cutlip v. Sec’y of Health & Hum. Servs., 25 F.3d 284 (6th Cir. 1994) (definition of substantial evidence)
Blakley v. Comm’r of Soc. Sec., 581 F.3d 399 (6th Cir. 2009) (review of conflicting evidence and substantial-evidence standard)
Walters v. Comm’r of Soc. Sec., 127 F.3d 525 (6th Cir. 1997) (ALJ credibility determinations entitled to deference)
Universal Camera Corp. v. NLRB, 340 U.S. 474 (U.S. 1951) (principle of weighing evidence and considering what detracts from administrative finding)